Case Law Update: State of Florida Ex Rel. Chertok v. Zillow — Florida Property Valuation Dispute

State of Florida, Ex Rel., Chertok v. Zillow, Inc.

Court: District Court of Appeal of Florida, First District
Date Filed: March 18, 2026
Docket Number: 1D2024-2804

Background

This case involves a qui tam action brought on behalf of the State of Florida against Zillow, Inc. concerning property valuation practices. While not a traditional property insurance case, the ruling has significant implications for how property values are assessed and disputed in Florida — directly relevant to insurance claim valuations.

Key Issues

The First District Court of Appeal addressed questions about property valuation methodology and the legal standards applicable to property assessments in Florida. The case raises important questions about the reliability and admissibility of automated valuation models (AVMs) in legal proceedings.

Court's Decision

The First DCA issued its ruling on the procedural and substantive aspects of the case, providing guidance on property valuation standards in Florida. The decision addresses the intersection of technology-driven property valuations and Florida's legal framework for property assessments.

Why This Matters for Public Adjusters

Property valuation is at the heart of every insurance claim. This case is relevant because:

• Insurance carriers increasingly rely on automated valuation tools to estimate property values and claim payouts
• The ruling may affect how courts view technology-based valuations in coverage disputes
• PAs challenging carrier valuations can use this precedent when arguing that automated estimates are unreliable
• It highlights the importance of independent appraisals and expert assessments in property claims

Practical Takeaway: When a carrier uses automated tools to lowball a property damage estimate, this case supports challenging those valuations with independent expert assessments. Always obtain your own contractor estimates and, when necessary, an independent appraisal to counter technology-driven underpayments.

Read the Full Opinion on CourtListener →

Practical Advice for Similar Cases

If the carrier or opposing party disputes property value or valuation methodology:

• Use multiple valuation sources. Supplement automated models with certified appraisals and comparable sales data.
• Challenge low carrier valuations with independent estimates from licensed contractors and detailed scope of work.
• Understand replacement cost vs. actual cash value. Review the policy to determine which standard applies.
• Document pre-loss property condition. Photos, tax assessments, and maintenance records establish baseline value.

Need help with a similar claim? Submit your policy for a free review by our property damage attorneys, or call us at 833-657-4812.