SFR Services, LLC v. American Coastal Insurance Company

CourtDistrict Court, M.D. Florida
DecidedFebruary 7, 2025
Docket2:22-cv-00505
StatusUnknown

This text of SFR Services, LLC v. American Coastal Insurance Company (SFR Services, LLC v. American Coastal Insurance Company) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SFR Services, LLC v. American Coastal Insurance Company, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION

SFR SERVICES, LLC, Plaintiff, v. Case No.: 2:22-cv-505-JLB-NPM

AMERICAN COASTAL INSURANCE COMPANY, Defendant. ____________________________________ ORDER SFR Services, LLC (“SFR”) sues American Coastal Insurance Company (“ACIC”) for breach of an insurance policy (the “Policy”) based on ACIC’s failure to provide coverage and remit payment for damage sustained by Steamboat Bend Condominium Association, Inc. (“Steamboat Bend”) during Hurricane Irma. (Doc. 53 at ¶¶ 5, 6, 9, 13–15). The Court granted SFR’s leave to amend the Complaint to include the July 2022 Assignment of Benefits (“AOB”) (Doc. 52). In light of the newly filed Amended Complaint (Doc. 53), the Court denied ACIC’s Motion for Summary Judgment (Doc. 54) as moot. ACIC moves again for summary judgment on all counts of the Amended Complaint, arguing that (1) SFR’s failure to fulfill its post-loss obligations was prejudicial to ACIC (Doc. 59 at 11–20); (2) Grant Renne, P.E.’s expert report fails to establish a genuine issue of material fact as to prejudice (id. at 20–21); (3) the claim was not reported within the three-year statutory requirement under Florida law (id. at 21–22); (4) the 2022 AOB is invalid and unenforceable (id. at 22–24), and (5) the Court lacks subject matter jurisdiction (id. at 24–25). SFR filed a response (Doc. 65), and ACIC replied (Doc. 73). Also before the Court, and related to the disposition of the motion for summary judgment, is ACIC’s Daubert Motion to exclude the expert testimony of Mr. Renne.1 (Doc. 58). SFR filed a response in

opposition. (Doc. 70). BACKGROUND This case is a dispute over ACIC’s denial of coverage after Steamboat Bend sustained property damage during Hurricane Irma. SFR is the assignee of Steamboat Bend’s rights under the Policy. (Doc. 59-26 at 1–3). The Policy’s post- loss obligations include: “prompt notice of the loss or damage,” permittance to examine and “make copies from your books and records,” and examinations under

oath (“EUOs”) if requested. (Doc. 59-2 at 16–17). The Policy provides that ACIC has “no duty to provide coverage . . . if the failure to comply with the . . . duties is prejudicial to [ACIC].” (Id. at 16). About six months after Hurricane Irma, Steamboat Bend submitted a claim to ACIC for damages sustained to the carport structures, which was denied. (Doc. 59-4; Doc. 59-5). Almost 2.5 years later, a supplemental claim was filed for

Hurricane Irma damage sustained by all the buildings. (Doc. 59-6). About six months after ACIC requested certain documents and after multiple follow-up requests, those documents were made available for copying. (Doc. 59-7; Doc. 59-11; Doc. 59-8 at 34, 51, 54–55). ACIC also invoked its right under the Policy

1 The motion for summary judgment argues that SFR is unable to rebut the presumption of prejudice with Mr. Renne’s report because it is “based on insufficient facts and data . . . .” (Doc. 59 at 20). to take EUOs of certain individuals. (Doc. 59-17). ACIC ultimately denied coverage because SFR’s failure to comply with its post-loss obligations prejudiced its ability to investigate the claim. (Doc. 59-20).

Mr. Renne conducted a virtual inspection assisted by Mr. Saint-Hilaire, a certified roofing inspector who was on-site during the inspection. (Doc. 58-6 at 30, 32). Mr. Renne’s methodology complied with standard practices and used data from the National Oceanic and Atmospheric Administration (NOAA) and the National Weather Service (NWS). (Doc. 58-2 at 1, 3; Doc. 58-6 at 24). Mr. Renne testified that he excluded from his analysis areas of prior repairs and areas of prior destructive testing. (Doc. 58-6 at 52–55, 69–70). Mr. Renne’s report ultimately

concluded that Hurricane Irma caused the damage. (Doc. 58-2 at 18). LEGAL STANDARDS I. Daubert Motion Opinion testimony by a “qualified” expert may be provided if the proponent of the expert demonstrates that it is more likely than not that:

(a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles; and (d) the expert has reliably applied the principles and methods to the facts of the case. Fed. R. Evid. 702. “Rule 702 compels the district courts to perform the critical ‘gatekeeping’ function concerning the admissibility of expert scientific evidence.” United States v. Frazier, 387 F.3d 1244, 1260 (11th Cir. 2004) (emphasis omitted) (quoting Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 589 n.7, 597 (1993)). The objective is to “ensure the reliability and relevancy of expert testimony.” Kumho Tire Co. v. Carmichael, 526 U.S. 137, 152 (1999). The “burden of laying the

proper foundation for the admission of expert testimony is on the party offering the expert, and the admissibility must be shown by a preponderance of the evidence.” McCorvey v. Baxter Healthcare Corp., 298 F.3d 1253, 1256 (11th Cir. 2002) (quotation omitted). A district court has “broad discretion in determining whether to admit or exclude expert testimony, and its decision will be disturbed on appeal only if it is manifestly erroneous.” Evans v. Mathis Funeral Home, 996 F.2d 266, 268 (11th Cir. 1993) (citations omitted).

II. Summary Judgment Summary judgment should be granted when “the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). If the movant meets that standard, the

burden shifts to the non-movant to “come forward with specific facts showing that there is a genuine issue for trial.” Shaw v. City of Selma, 884 F.3d 1093, 1098 (11th Cir. 2018) (internal quotation marks omitted). Disputes are genuine if “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). Facts are material if they may “affect the outcome of the suit under the governing law.” Id. The Court’s function is not to “weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for trial.” Id. at 249. DISCUSSION I. The Daubert Motion. Mr. Renne has been a Registered Professional Engineer since 1990, completed over 6,000 property damage investigations throughout his career, and participated in over 400 cases. (See Doc. 44-2). The Court finds that he is qualified

to provide an expert opinion on this matter. In fact, the Daubert Motion challenges only the reliability of Mr. Renne’s conclusions and whether his opinion is predicated upon sufficient facts and data. (Doc. 58). When ascertaining the reliability of an expert’s opinion, courts consider, amongst other things: “(1) whether the expert’s theory can be and has been tested; (2) whether the theory has been subjected to peer review and publication; (3) the

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SFR Services, LLC v. American Coastal Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sfr-services-llc-v-american-coastal-insurance-company-flmd-2025.