Thomas A. Bouchard, Jr. v. Citizens Property Insurance Corporation

CourtDistrict Court of Appeal of Florida
DecidedFebruary 19, 2025
Docket3D2023-2202
StatusPublished

This text of Thomas A. Bouchard, Jr. v. Citizens Property Insurance Corporation (Thomas A. Bouchard, Jr. v. Citizens Property Insurance Corporation) 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
Thomas A. Bouchard, Jr. v. Citizens Property Insurance Corporation, (Fla. Ct. App. 2025).

Opinion

Third District Court of Appeal State of Florida

Opinion filed February 19, 2025. Not final until disposition of timely filed motion for rehearing.

________________

No. 3D23-2202 Lower Tribunal No. 22-CA-295-K ________________

Thomas A. Bouchard, Jr., Appellant,

vs.

Citizens Property Insurance Corporation, Appellee.

An Appeal from the Circuit Court for Monroe County, Mark Wilson, Judge.

Weber, Crabb & Wein, P.A., and Jeremy D. Bailie, and Sandford Blaine Kinne (St. Petersburg), for appellant.

Luks, Santaniello, Petrillo, Cohen & Peterfriend and Daniel S. Weinger (Fort Lauderdale), for appellee.

Before FERNANDEZ, LINDSEY, and MILLER, JJ.

LINDSEY, J. Appellant, Plaintiff below, Thomas A. Bouchard, Jr. appeals from a

Final Summary Judgment entered in favor of Appellee, Defendant below,

Citizens Property Insurance Corp. The trial court determined that

Bouchard’s notice of claim, which was filed over 13 months after Bouchard

became aware of property damage allegedly caused by Tropical Storm Eta,

was untimely. The trial court further determined that Bouchard failed to rebut

the resulting presumption of prejudice. The only issue before us is whether

the trial court erred in determining that Bouchard did not rebut the

presumption of prejudice. Because the court did not err, we affirm.

I. BACKGROUND

This breach of insurance contract case arises from Bouchard’s

allegations that his home in Key West was damaged by Tropical Storm Eta

on November 8, 2020. The following facts are undisputed. At the time of

the storm, Bouchard was insured under a Citizens residential insurance

policy. He noticed water leaking through his roof on the day of the storm.

Despite observing leaks during the storm, Bouchard waited over 13 months,

until December 22, 2021, to submit a Sworn Proof of Loss to Citizens.1

Bouchard did not submit an estimate until February 16, 2022.

1 In his deposition, Bouchard explained that he waited over a year to report the damage because “it’s almost how long it took my divorce, and I didn’t want to make a claim on the home when I didn’t know if it was going to be my home.” 2 Citizens’ field adjuster inspected the property on January 20, 2022. On

February 15, 2022, Citizens denied Bouchard’s claim for failure to timely

report the loss:

Based on all of the information gathered to date, there is insufficient evidence to substantiate a loss related to Wind - TS ETA on 11/08/2020.

Citizens’ ability to evaluate this claim has been prejudiced due to failure to report this loss in a timely manner; therefore, the claimed loss is excluded from coverage under the policy.

Citizens’ denial letter also referenced the “Conditions” section in the policy,

which imposes a duty on the insured to provide prompt notice.

In April 2022, Bouchard sued Citizens for breach of the insurance

policy. Citizens moved for summary judgment, arguing that due to

Bouchard’s delay in reporting the loss, Citizens was presumed prejudiced,

and that Bouchard could not rebut said presumption. In response, Bouchard

argued that factual questions existed as to the timeliness of the notice and

whether Citizens was prejudiced. In support of rebutting the presumption of

prejudice, Bouchard attached a June 2023 Affidavit prepared by a licensed

engineer stating that Tropical Storm Eta caused the reported damage. The

relevant portion of the Affidavit is as follows:

Pursuant to my investigation, it is my conclusion and professional opinion that Tropical Storm ETA, which affected the State of Florida between the dates of November 7, 2020, and

3 November 12, 2020, is the proximate weather event that caused the damages documented during the field walk-thru to the subject property.

The Affidavit referenced and purported to attach an Engineering Report;

however, the Report was not attached.

The trial court conducted a hearing on Citizens’ motion. At the

beginning of the hearing, the court determined that “Bouchard was aware of

[the loss] at the time of the storm and he didn’t report it to the insurance

company for 13 and a half months, it would seem to me, as a matter of law,

that’s not prompt notice.” The primary focus of the hearing was whether

Bouchard rebutted the presumption of prejudice that resulted from the

untimely notice. Counsel for Bouchard initially relied on the Engineer’s

Affidavit. When the trial court pointed out that the Affidavit—prepared two

and a half years after Tropical Storm Eta—appeared conclusory, counsel for

Bouchard attempted to rely on the Engineering Report, which had not been

provided to the court or to opposing counsel.

The trial court granted Citizens’ Motion for Summary Judgment,

concluding that Bouchard’s “notice of claim was untimely and that he failed

to adequately rebut the presumption of prejudice resulting from the untimely

notice.” Bouchard filed the missing Engineering Report and moved for

4 rehearing.2 The court entered a detailed order denying rehearing and

concluding that the Report, like the Affidavit, was conclusory. Bouchard

timely appealed.3

II. ANALYSIS

We review orders granting final summary judgment de novo. See, e.g.,

Bejarano v. City of Coral Gables, 300 So. 3d 712, 713 (Fla. 3d DCA 2019).

“[A] lower court’s ruling on the legal sufficiency of an affidavit is also reviewed

de novo.” United Auto. Ins. Co. v. Progressive Rehab. & Orthopedic Servs.,

LLC, 324 So. 3d 1006, 1008 (Fla. 3d DCA 2021).

“The purpose of a provision for notice and proofs of loss is to enable

the insurer to evaluate its rights and liabilities, to afford it an opportunity to

make a timely investigation, and to prevent fraud and imposition upon it.”

Perez v. Citizens Prop. Ins. Corp., 343 So. 3d 140, 142 (Fla. 3d DCA 2022)

(quoting State Farm Mut. Auto. Ins. Co. v. Ranson, 121 So. 2d 175, 180 (Fla.

2d DCA 1960), overruled in part on other grounds, Am. Fire & Cas. Co. v.

Collura, 163 So. 2d 784, 793–94 (Fla. 2d DCA 1964)).

2 Citizens did not object to Bouchard filing the Engineering Report. 3 Bouchard appealed before the trial court ruled on his Motion for Rehearing. Consequently, this Court held the appeal in abeyance for the trial court to adjudicate the pending motion. See Fla. R. App. P. 9.020(h)(2)(C). 5 Issues related to timely reporting a loss are reviewed under a two-part

analysis. Navarro v. Citizens Prop. Ins. Corp., 353 So. 3d 1276, 1279 (Fla.

3d DCA 2023). The first step is to determine whether notice was timely. Id.

Though timeliness was at issue below, on appeal, Bouchard does not contest

the trial court’s determination that notice was untimely. If notice is untimely,

a rebuttable presumption of prejudice to the insurer arises and the analysis

proceeds to the second step. See, e.g., LoBello v. State Farm Fla. Ins. Co.,

152 So. 3d 595, 599 (Fla. 2d DCA 2014). The second step is to determine

whether the insurer satisfies the burden of overcoming this presumption of

prejudice. Id.

In support of his argument rebutting the presumption of prejudice,

Bouchard primarily relies on Shapiro v.

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Related

State Farm Mutual Automobile Insurance Co. v. Ranson
121 So. 2d 175 (District Court of Appeal of Florida, 1960)
American Fire and Casualty Company v. Collura
163 So. 2d 784 (District Court of Appeal of Florida, 1964)
DIVISION OF ADMIN., ETC. v. Samter
393 So. 2d 1142 (District Court of Appeal of Florida, 1981)
Gonzalez v. Citizens Property Ins. Corp.
273 So. 3d 1031 (District Court of Appeal of Florida, 2019)
LoBello v. State Farm Florida Insurance Co.
152 So. 3d 595 (District Court of Appeal of Florida, 2014)

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Thomas A. Bouchard, Jr. v. Citizens Property Insurance Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-a-bouchard-jr-v-citizens-property-insurance-corporation-fladistctapp-2025.