Case Law Update: FIGA v. Steve Cadet — Florida Insurance Guaranty Association Liability Dispute

Florida Insurance Guaranty Association v. Steve Cadet

Court: District Court of Appeal of Florida, Fourth District
Date Filed: March 18, 2026
Docket Number: 4D2024-2631

Background

This case involves the Florida Insurance Guaranty Association (FIGA) and its obligations to policyholder Steve Cadet following the insolvency of his property insurance carrier. When an insurance company becomes insolvent in Florida, FIGA steps in under Florida Statute 631.57 to process covered claims — but disputes frequently arise over the scope of FIGA's liability.

Key Issues

The central question before the Fourth DCA was whether FIGA properly handled the claim obligations transferred to it upon the carrier's insolvency. The policyholder argued that FIGA's handling of the claim fell short of the statutory requirements, while FIGA contended its obligations were limited under the guaranty fund statute.

Court's Decision

The Fourth District Court of Appeal issued its ruling addressing the scope of FIGA's claim processing duties and the timeline requirements under Chapter 631 of the Florida Statutes. The decision provides important clarification on the interplay between FIGA's statutory obligations and policyholder rights when a carrier goes insolvent.

Why This Matters for Public Adjusters

With several Florida property insurance carriers facing financial difficulties in recent years, FIGA claims have become increasingly common. Public adjusters working with policyholders whose carriers have gone insolvent need to understand:

• FIGA's statutory obligations under F.S. 631.57
• The timeline requirements for FIGA claim processing
• How to properly preserve policyholder rights during the FIGA process
• When legal referral may be necessary to protect the insured's interests

Practical Takeaway: If you are handling a claim where the carrier has been declared insolvent, document everything meticulously and ensure all FIGA deadlines are met. This ruling reinforces that FIGA must fulfill its statutory duties — and policyholders have legal recourse when it does not.

Read the Full Opinion on CourtListener →

Practical Advice for Similar Cases

If you are handling a claim where the original carrier has become insolvent and FIGA has assumed responsibility:

• File early and document everything. FIGA claims have strict statutory deadlines. Ensure your policyholder files proof of claim within the required timeframe.
• Understand FIGA coverage caps. FIGA has statutory limits per claim under F.S. 631.57.
• Preserve the original claim file. All documentation from the original carrier becomes critical evidence when FIGA takes over.
• Refer to counsel early. FIGA disputes involve complex statutory interpretation that benefits from attorney involvement.

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.