FLORIDA CIVIL REMEDY NOTICE VALID DESPITE NO SPECIFIC CURE AMOUNT.

In Lugassy v. Utd. Prop. & Cas. Ins. Co., ___ So. 3d ___, No. 4D21-2929, 2022 WL 17171368, at *2 (Fla. 4th DCA Nov. 23, 2022), a Civil Remedy Notice of Insurer Violation ("CRN") of Florida's Bad Faith Statute was held to comply with the Florida Statute:

    Here, the Homeowners’ CRN listed the specific statutory provisions that United allegedly violated, referenced the specific policy language relevant to the violations, and gave a detailed recitation of the facts surrounding the violation.

In particular, the appellate court held that the trial court was wrong to accept the carrier's argument in this case that the CRN has to show a specific amount for the carrier to pay to cure its alleged bad faith.  The CRN does not need to show a specific cure amount in order to qualify as a proper CRN under the Florida Bad Faith Statute:

    Regarding the trial court's determination that the CRN was invalid because the “cure” amount was unclear, we reject this determination as Florida law does not require a CRN to include a specific cure amount. 

Lugassy, 2022 WL 17171368, at *3.

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