UNIVERSAL PROPERTY CASUALTY INSURANCE COMPANY v. MOYA (2024)

Universal Property & Casualty Insurance Company appeals a final judgment in favor of Gerardo Moya. Moya filed suit against Universal for breach of contract and for declaratory relief after Universal failed to pay Moya's first-party insurance claim. During the jury trial, Universal moved for a directed verdict on the grounds that the evidence Moya presented for damages was legally insufficient because there was no record evidence to give a jury a reasonable basis to determine damages without speculation. The trial court denied Universal's motion for directed verdict.

On appeal, Universal maintains that Moya did not present the requisite damages evidence at trial. We agree. See, e.g., United Auto. Ins. Co. v. Colon, 990 So. 2d 1246, 1248 (Fla. 4th DCA) (“It has long been accepted in Florida that a party claiming economic losses must produce evidence justifying a definite amount. Economic damages may not be founded on jury speculation or guesswork and must rest on some reasonable factual basis.” (citations omitted)).

Reversed.

PER CURIAM.