CAMACHO v. CITIZENS PROPERTY INSURANCE CORPORATION (2026)

In this first-party property insurance dispute, the insured, appellant, Francia Camacho, appeals from a final summary judgment rendered in favor of her insurer, appellee, Citizens Property Insurance Corporation. Having reviewed the summary judgment record de novo, as we must, we discern no error in the trial court's carefully reasoned conclusion that the nearly three-year delay in reporting purported Hurricane Irma-related damage to the residence insurmountably stymied the insurer's ability to evaluate, investigate, and adjust the claim. See Volusia Cnty. v. Aberdeen at Ormond Beach, L.P., 760 So. 2d 126, 130 (Fla. 2000) (reviewing court employs a de novo standard in appeal from a summary judgment); see also Navarro v. Citizens Prop. Ins. Corp., 353 So. 3d 1276, 1278–80 (Fla. 3d DCA 2023) (affirming an order granting summary judgment for the underlying insurance claim when “[appellant] waited two years and seven months to report the claim” and therefore “[appellant] failed to overcome the presumption [that] Citizens was prejudiced as the result of his failure to timely report his claim”). Accordingly, we affirm the judgment in all respects.

Affirmed.

MILLER, J.