Case Analysis: Fifth District Court of Appeal Holds That Florida’s Bad Faith Statute Does Not Apply To Citizens

Jan 27, 2010


In a December 18, 2009 opinion on Citizens Property Insurance Corp. v. Garfinkel, the Fifth District Court of Appeal held that, not only was Citizens Property Insurance Corporation (“Citizens”) immune from first-party bad faith claims, but that Florida’s bad faith statute does not apply to Citizens. 

An analysis of the case is attached.


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