Seneca Specialty Insurance Company v. Jade Beach Condominium Association, Inc., etc.

CourtDistrict Court of Appeal of Florida
DecidedApril 3, 2024
Docket2022-1290
StatusPublished

This text of Seneca Specialty Insurance Company v. Jade Beach Condominium Association, Inc., etc. (Seneca Specialty Insurance Company v. Jade Beach Condominium Association, Inc., etc.) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Seneca Specialty Insurance Company v. Jade Beach Condominium Association, Inc., etc., (Fla. Ct. App. 2024).

Opinion

Third District Court of Appeal State of Florida

Opinion filed April 3, 2024. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D22-1290 Lower Tribunal No. 20-13123 ________________

Seneca Specialty Insurance Company, Appellant,

vs.

Jade Beach Condominium Association, Inc., etc., et al., Appellees.

An Appeal from the Circuit Court for Miami-Dade County, David C. Miller, Judge.

Kennedys CMK LLP, and Josh Levy, Martin F. Harms, and Jedidiah Vander Klok, for appellant.

Boyle, Leonard, & Anderson, P.A., and Alexander Brockmeyer (Fort Myers), for appellees.

Before LOGUE, C.J., and SCALES and GORDO, JJ.

LOGUE, C.J.

 Judge Gordo did not participate in oral argument. Seneca Specialty Insurance Company appeals the trial court’s order

dismissing its breach of contract action against Seneca’s insured, Jade

Beach Condominium Association, Inc. In the operative complaint, Seneca

alleged the Association violated the policy provisions requiring the

Association to refrain from impairing Seneca’s subrogation rights when the

Association settled with, and released, tortfeasors responsible for claims that

had been brought by third parties against the Association, and which Seneca

had paid on the Association’s behalf. The narrow issue on appeal is whether

Seneca sufficiently stated a breach of contract claim by alleging the

Association’s releases barred its subrogation rights and attaching the policy

and releases. The trial court ruled that the complaint failed to state a claim

because, in these circumstances, an insurer must allege it first sued the

responsible tortfeasors and suffered a judgment finding that the insured’s

releases barred its subrogation rights. For the reasons stated below, we

conclude that Seneca sufficiently pled its claim. Thus, we reverse the trial

court’s dismissal of Seneca’s breach of contract claim.1

1 We affirm the trial court’s dismissal with prejudice of Seneca’s remaining claims.

2 BACKGROUND

Seneca issued a liability insurance policy to the Association that

required the Association to refrain from impairing Seneca’s subrogation

rights against responsible tortfeasors. The policy stated:

If the insured has rights to recover all or part of any payment we have made under this Coverage Part, those rights are transferred to us. The insured must do nothing after loss to impair them. At our request, the insured will bring "suit" or transfer those rights to us and help us enforce them.

On August 1, 2014, the owners of Unit 4701 at Jade Beach

Condominium (“Unit 4701”) sued the Association, the owner of Unit 4904

(“Unit 4904"), and two construction companies, among others. Unit 4701

alleged that water flowing down from Unit 4904’s balcony and from limited

common areas appurtenant to Unit 4904 caused damage to their balcony.

Unit 4701 contended the Association had a non-delegable responsibility to

maintain the structural and mechanical elements of the Unit 4904 balcony,

which was a limited common element. Based on these allegations, Unit 4701

alleged claims against the Association for breach of the declaration of

condominium, trespass, and nuisance.

Unit 4904 then filed a crossclaim against the Association and alleged

claims for breach of the condominium’s declaration, contribution, common

law indemnification, and equitable subrogation (“Unit 4904’s Crossclaim”).

3 Unit 4904 argued the Association had a duty to maintain the condominium’s

common elements and to remedy any structural defects. As such, they

contended, the Association had a duty to remedy the water run-off from Unit

4904’s balcony and to remedy water intrusion into Unit 4904 because these

issues arose from underlying structural issues with common and limited

common elements.

When notified by the Association of the lawsuits, and as required by

the policy, Seneca provided the Association with a defense and ultimately

paid its liability policy limit of $1,000,000 on behalf of the Association to settle

Unit 4904’s Crossclaim.

Unbeknownst to Seneca, however, while these unit owner actions

were pending, the Association filed a separate construction defect lawsuit

against the condominium developer, general contractor, design

professionals, and subcontractors, including the concrete formwork

subcontractor, the mechanical subcontractor, and the caulking and

waterproofing subcontractor (collectively, “the Construction Defect

Defendants”). The Association’s lawsuit (the “Construction Defect Lawsuit”)

included allegations of defects in mechanical rooms causing leakage into

units below, defects in roofs, and defects in balcony slopes. In addition to

damages, the Association sought indemnification from the Construction

4 Defect Defendants for all unit owner claims brought against the Association

arising from the defects.

The Association resolved the Construction Defect Lawsuit through

various settlements totaling approximately $12,565,000. The settlement

amounts were not allocated to any particular claims. As part of the

settlement, the Association gave the Construction Defect Defendants

general releases of the Association’s claims. For example, one of the

releases provided:

[T]he Association, for themselves and each of their respective . . . insurers hereby mutually release and forever discharge [the general contractor] and each of their respective . . . insurers, . . . and any person or entity that provided labor, materials or services under a direct contract with [the general contractor] related to the construction of the [condominium], from any and all manner of past, present and future claims, actions, causes and causes of action, suits, lawsuits, debts, dues, duties, sums of money, accounts, reckonings, bonds, bills, specialties, covenants, contracts, liabilities, statutory claims for damages, exemplary and/or punitive damages, claims for indemnity or contribution, controversies, expenses, assessments, penalties, charges, injuries, losses, fees, costs, damages, expenses, agreements, promises, variances, trespasses, judgments, executions, and demands whatsoever, in law or in equity, which they ever had, now have, will have, or may have in the future, against each other, both known and unknown, latent and patent, asserted and unasserted, suspected and unsuspected, discovered and undiscovered, whether now existing, or hereafter arising, that relate to, arise

5 out of, or are in any way connected with, the original construction of the [condominium], including but not limited to all claims which were or could have been asserted in the [Construction Defect Lawsuit].

(emphasis added).

The Association allegedly did not inform Seneca of these settlements

at any time before Seneca paid its liability policy limit to settle Unit 4904’s

Crossclaim, and Seneca was not a party to the Construction Defect Lawsuit

or the settlement agreements.

On June 22, 2020, Seneca filed the underlying action against the

Association. The operative complaint included a breach of contract claim

against the Association, arguing the Association impaired Seneca’s

subrogation rights by releasing the Construction Defect Defendants in the

Construction Defect Lawsuit. Attached to the complaint were copies of the

Association’s releases given to the Construction Defect Defendants. The

complaint alleged the Association’s releases barred Seneca’s subrogation

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Seneca Specialty Insurance Company v. Jade Beach Condominium Association, Inc., etc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/seneca-specialty-insurance-company-v-jade-beach-condominium-association-fladistctapp-2024.