UNIVERSAL PROPERTY CASUALTY INSURANCE COMPANY v. GRIFFIN (2026)

District Court of Appeal of Florida, Fourth District.

UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY, Appellant, v. Jada GRIFFIN, Appellee.

No. 4D2024-1332

Decided: April 22, 2026

David A. Noel and Kara Rockenbach Link of Link & Rockenbach, P.A., West Palm Beach, for appellant. Robert C. Hubbard and George A. Vaka of Vaka Law Group, P.L., Tampa, for appellee.

ON MOTION TO CERTIFY CONFLICT

The plaintiff filed a motion to certify conflict, requesting that we certify that our decision is in express and direct conflict with the decisions in Hughes v. Universal Prop. & Cas. Ins. Co., 374 So. 3d 900, 910 (Fla. 6th DCA 2023), review granted, No. SC2024-0025, 2024 WL 1714497 (Fla. Apr. 22, 2024), Cantens v. Certain Underwriters at Lloyd's London, 388 So. 3d 242 (Fla. 3d DCA 2024), and Smith v. Universal Prop. & Cas. Ins. Co., 396 So. 3d 860 (Fla. 5th DCA 2024). In its response, the insurer indicates it has no objection but clarified the cases with which our decision conflicts.

We therefore certify express and direct conflict with the following decisions:

• Hughes v. Universal Prop. & Cas. Ins. Co., 374 So. 3d 900 (Fla. 6th DCA 2023), review granted, 2024 WL 1714497 (Fla. Apr. 22, 2024);

• Buis v. Universal Prop. & Cas. Ins. Co., 394 So. 3d 738 (Fla. 2d DCA 2024); and

• Smith v. Universal Prop. & Cas. Ins. Co., 396 So. 3d 860 (Fla. 5th DCA 2024).

Question Certified.

May, J.

Conner and Lott, JJ., concur.

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