Case Law Update: Riley Love v. Florida Family Insurance — Appraisal Dispute in Property Claim

Riley Love v. Florida Family Insurance Company

Court: District Court of Appeal of Florida, Third District
Date Filed: March 11, 2026
Docket Number: 3D2025-2537

Background

Riley Love filed a property insurance claim with Florida Family Insurance Company, one of Florida's domestic property insurers. When the parties could not agree on the amount of loss, the dispute escalated to the appraisal process — a mechanism provided in most Florida property insurance policies to resolve valuation disagreements.

Key Issues

The case centered on the appraisal process under the insurance policy. Disputes over appraisal frequently arise in Florida property insurance cases, particularly regarding whether appraisal can address coverage questions or only the amount of loss, and whether a carrier can delay or refuse to participate in the appraisal process.

Court's Decision

The Third District Court of Appeal weighed in on the appraisal dispute, addressing the carrier's obligations when an insured invokes the appraisal clause. The ruling provides guidance on the proper scope and procedure for appraisal in Florida property insurance disputes.

Why This Matters for Public Adjusters

Appraisal is one of the most powerful tools available to public adjusters and policyholders when carriers underpay claims. This ruling from the Third DCA is significant because:

• It clarifies when and how appraisal can be invoked against Florida domestic carriers
• It addresses carrier obligations once appraisal is properly demanded
• It reinforces the distinction between coverage disputes (not appraisable) and amount-of-loss disputes (appraisable)
• It provides precedent for PAs advising clients on whether to pursue appraisal vs. litigation

Practical Takeaway: When negotiating with Florida Family Insurance or similar carriers, this case strengthens the policyholder's position in demanding appraisal for underpayment disputes. Document the carrier's valuation versus your estimate thoroughly — appraisal remains a faster and less expensive alternative to litigation for resolving amount disputes.

Read the Full Opinion on CourtListener →

Practical Advice for Similar Cases

If the carrier disputes the appraisal process or your policyholder's right to invoke appraisal:

• Know the appraisal clause. Review the exact provision in the policy. Timing and scope limitations vary by carrier.
• Invoke appraisal in writing. Send demands via certified mail. Carriers may argue waiver if not properly invoked.
• Select a qualified appraiser with specific experience in the type of damage at issue.
• Don't confuse appraisal with coverage. Appraisal determines loss amount, not whether loss is covered. If coverage is denied entirely, litigation may be necessary.

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.