United Specialty Insurance Company v. Advanced Wrapping and Concrete Solutions of Central Florida, Inc.

CourtDistrict Court, M.D. Florida
DecidedFebruary 19, 2026
Docket6:25-cv-01353
StatusUnknown

This text of United Specialty Insurance Company v. Advanced Wrapping and Concrete Solutions of Central Florida, Inc. (United Specialty Insurance Company v. Advanced Wrapping and Concrete Solutions of Central Florida, Inc.) 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
United Specialty Insurance Company v. Advanced Wrapping and Concrete Solutions of Central Florida, Inc., (M.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION

UNITED SPECIALTY INSURANCE COMPANY,

Plaintiff,

v. Case No: 6:25-cv-1353-PGB-DCI

ADVANCED WRAPPING AND CONCRETE SOLUTIONS OF CENTRAL FLORIDA, INC.,

Defendant.

ORDER United Specialty Insurance Company (Plaintiff) brings this declaratory action against Advanced Wrapping and Concrete Solutions of Central Florida, Inc. (Defendant). Doc. 1. Pending before the Court is Plaintiff’s Motion for Default Judgment. Doc. 18 (the Motion). Defendant has not filed a response to the Motion, but it is still due to be denied. Plaintiff alleges that Hawksmoor Community Owners (Hawksmoor) filed a construction- defect lawsuit in state court against the developer, general contractor, and subcontractors including Defendant—Case No. 2024-CA-008623-0 (the Underlying Lawsuit). Id. at 2. In the Underlying Lawsuit, Hawksmoor alleges that Defendant served as a “subcontractor responsible for the installation of the housewrap, waterproofing systems, flashing, and related elements at the Community.” Doc. 1-2 at 10. Hawksmoor brings a claim against the defendants for “damages arising from the negligent and defective development, construction, and sale of the townhouses and common areas. . . at the Hawksmoor townhome community located in Orange County, Florida[.]” Id. at 4. In the instant action, Plaintiff claims that it issued a commercial general liability policy to Defendant with a policy period from March 31, 2018 to March 31, 2019. Doc. 1 at 3. Plaintiff alleges that the insurance policy includes certain exclusions, and the Hawksmoor project was not exempted from the Condo/Townhouse Exclusions. Id. at 7. As such, Plaintiff contends that “there is no insurance coverage for the claims arising out of the Hawksmoor townhouse community as

alleged in the Underlying Complaint.” Id. Plaintiff claims that the allegations in the underlying complaint trigger the Condo/Townhouse Exclusions in the insurance policy and, Plaintiff, therefore “owes no defense or indemnity obligations to [Defendant] or anyone else seeking coverage under the Policy for the claims arising out of the Hawksmoor townhome community as alleged in the Underlying Complaint.” Id. at 8. Plaintiff brings one count for declaratory judgment that the policy at issue provides no coverage to Defendant with respect to the underlying complaint. Id. Defendant has not appeared in this matter and, therefore, Plaintiff moved for Clerk’s Entry of Default pursuant to Federal Rule of Civil Procedure 55(a). Doc. 14. The Clerk entered default,

and Plaintiff now moves for default judgment against Defendant under Rule 55(b)(1). Doc. 18. But before entering default judgment, the Court must ensure that it has jurisdiction over the claims and parties, and that the well-pled factual allegations of a complaint, which are assumed to be true, adequately state a claim for which relief may be granted. See Nishimatsu Constr. Co. v. Houston Nat’l Bank, 515 F.2d 1200, 1206 (5th Cir. 1975).1 It is also Plaintiff’s burden to address the elements of the causes of action and the specific, well-pled facts in the operative complaint that

1 The Eleventh Circuit adopted as binding precedent all decisions of the former Fifth Circuit handed down prior to the close of business on September 30, 1981. Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc). satisfy each of those elements. Riley v. Marcino, 2026 U.S. Dist. LEXIS, at *2 (M.D. Fla. Feb. 11, 2026) (citation omitted). The Motion fails because Plaintiff does not mention jurisdiction, nor does it sufficiently address the elements of the one cause of action. Turning to the Complaint, Plaintiff pleads that the Court has jurisdiction pursuant to 28 U.S.C. § 1332, as there is complete diversity of citizenship

between the parties and the amount in controversy exceeds $75,000.00, exclusive of fees and costs. Doc. 1 at 2. While it appears that the parties are completely diverse, the Court questions whether the jurisdictional amount is met. This is a case for declaratory judgment and not damages, and Plaintiff does not address how the Court should arrive at the appropriate figure for purposes of deciding the amount in controversy. Although not briefed, the Court recognizes that “[w]hen an insurer seeks a declaration that it has ‘no duty to defend nor indemnify an insured in an underlying lawsuit,’ the amount in controversy is determined by examining the following factors: ‘(1) the coverage limits under the insurance policy; (2) the amount of damages sought in the underlying lawsuit; and (3)

the pecuniary value of the obligation to defend the underlying lawsuit.’” Southern-Owners Ins. Co. v. Maronda Homes, Inc., 2019 WL 2929715, at *2 (M.D. Fla. July 8, 2019) (quoting Clarendon Am. Ins. Co. v. Miami River Club, Inc., 417 F. Supp. 2d 1309, 1316 (S.D. Fla. 2006)). With respect to the insurance limits, Plaintiff attaches the policy to the Complaint, and it appears that coverage is above $75,000.00 (see Doc. 1-3), but Plaintiff makes no mention of the policy limit in the Motion or Complaint. See Docs. 1, 18. And “‘[w]hile a low policy limit may be relevant in showing that the monetary value of the action to the insurer does not reach the jurisdictional threshold, . . . a high policy limit does not establish a large amount in controversy for the simple reason that the underlying plaintiff’s claim may be for far less than the policy limit.’” Maronda Homes, 2019 WL 2929715, at *2 (quoting Emp’rs Mut. Cas. Co. v. Parker Towing Co., 2007 WL 4577705, at *2 (S.D. Ala. Dec. 27, 2007)); see also Amerisure Ins. Co. v. Island Crowne Developers, L.C., 2010 WL 11626694, at *2 (M.D. Fla. Apr. 28, 2010) (“[A] showing that the policy amount exceeds $75,000 does not in and of itself establish that the amount in controversy

requirement has been met because the value of the underlying claim may be for less than the policy limits[.]”) (citing Hartford Insurance Group v. Lou-Con. Inc., 293 F.3d 908, 911 (5th Cir. 2002) (“[I]n declaratory judgment cases that involve the applicability of an insurance policy to a particular occurrence, the jurisdictional amount in controversy is measured by the value of the underlying claim—not the face amount of the policy.”)). To the extent Plaintiff relies on the policy limits, Plaintiff must address that factor as it relates to the amount in controversy. And with respect to damages, “when a declaratory judgment action seeks judgment declaring an insurer’s liability on a particular occurrence. . . the amount in controversy is measured by the value of the underlying claim, not the policy limits.” Conklin Onebeacon Am. Ins. Co.,

2018 WL 3850012, at *2 (M.D. Fla. Mar. 12, 2018). The Court cannot say what the actual value of the claim is because Plaintiff does not offer that information. Plaintiff does provide the Court with the complaint from the Underlying Lawsuit, but Hawksmoor pleads only that it “brings th[e] action to recover its damages, which exceed $50,000.00, exclusive of interest, costs, and attorneys’ fees.” Doc. 1-2 at 6. Clearly that amount is not sufficient to reflect that the jurisdictional threshold is met in the instant case.

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Bluebook (online)
United Specialty Insurance Company v. Advanced Wrapping and Concrete Solutions of Central Florida, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-specialty-insurance-company-v-advanced-wrapping-and-concrete-flmd-2026.