Insurer’s Failure to Raise Deficiency in Civil Remedy Notice at Appropriate Stage Amounts to Waiver of Argument at Summary Judgment

Frisco v State Farm Fla. Ins. Co., Case No. 2D2024-0464 (Fla 2nd DCA December 3, 2025). The plaintiffs appealed a final summary judgment granted in favor of State Farm in their bad faith lawsuit. The Friscos filed a homeowner’s insurance claim based on damage due to a contractor’s faulty work and later, filed a Civil Remedy Notice (CRN), frustrated by State Farm’s claim handling. The Friscos then filed a breach of contract action and State Farm responded by demanding appraisal. The trial court... By: Marshall Dennehey