In the recent decision Universal Property & Casualty Insurance Co. v. Qureshi, the Florida Fourth District Court of Appeal held that homeowners cannot recover replacement cost benefits unless they have incurred expenses for repairs. The court emphasized that under both the insurance policy’s plain language and Florida Statute §627.7011(3)(a), payment of replacement cost value is contingent upon the actual completion of repairs. The ruling reversed a jury award for homeowners who had sold their property without performing the necessary repairs, addressing a crucial question about recovery for unperformed repairs in property insurance claims.
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