Universal Property & Casualty Insurance Company v. Jada Griffin
Docket 4D2024-1332
Court of record · Indexed in NoticeRegistry archive · AI-enriched for research
- Filed
- Jurisdiction
- Florida
- Court
- District Court of Appeal of Florida
- Type
- Opinion
- Case type
- Civil
- Docket
- 4D2024-1332
Order on a motion to certify conflict from an appeal in a civil insurance action in the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach County.
Summary
The Fourth District Court of Appeal granted the plaintiff's motion to certify that its decision conflicts with other Florida district court opinions. The court expressly certified conflict with three identified decisions from other districts involving Universal Property & Casualty Insurance Company and related insurers. The opinion simply identifies the conflicting cases and certifies the question of conflict for resolution by the Florida Supreme Court, noting the matter is not final until disposition of any timely rehearing. No substantive merits ruling is made in this order.
Issue Decided
- Whether this court's decision is in express and direct conflict with prior district court decisions addressing similar issues involving Universal Property & Casualty Insurance Company and related insurers.
Court's Reasoning
The court reviewed the motion and the insurer's response and concluded that its decision is in express and direct conflict with specified decisions from the Second, Fifth, and Sixth District Courts of Appeal. Because the presence of district-court conflict is a jurisdictional and procedural matter for the supreme court to resolve, the court certified the question rather than resolving the underlying substantive legal issues. The court noted the certification and preserved rehearing rights.
Authorities Cited
- Hughes v. Universal Prop. & Cas. Ins. Co.374 So. 3d 900 (Fla. 6th DCA 2023), review granted, No. SC2024-0025, 2024 WL 1714497 (Fla. Apr. 22, 2024)
- Buis v. Universal Prop. & Cas. Ins. Co.394 So. 3d 738 (Fla. 2d DCA 2024)
- Smith v. Universal Prop. & Cas. Ins. Co.396 So. 3d 860 (Fla. 5th DCA 2024)
Parties
- Appellant
- Universal Property & Casualty Insurance Company
- Appellee
- Jada Griffin
- Judge
- Gerard J. Curley Jr.
- Judge
- MAY, J.
- Judge
- CONNER, J.
- Judge
- LOTT, J.
Key Dates
- District Court decision date
- 2026-04-22
What You Should Do Next
- 1
Consider timely motion for rehearing
If a party believes there are grounds, file a motion for rehearing in the Fourth District within the applicable deadline to seek reconsideration before the certification proceeds.
- 2
Prepare for potential Florida Supreme Court review
If the conflict is accepted, parties should prepare merits briefs and records for the Florida Supreme Court, focusing on the points of conflict identified among the district court decisions.
- 3
Consult appellate counsel
Parties should consult or retain appellate counsel experienced in Florida Supreme Court practice to strategize on preserving issues and presenting arguments on the certified conflict.
Frequently Asked Questions
- What did the court decide?
- The court certified that its ruling conflicts with other district court decisions and submitted the question of conflict for the Florida Supreme Court to address; it did not decide the underlying insurance dispute's merits.
- Who is affected by this certification?
- The parties to this appeal (Universal Property & Casualty Insurance Company and Jada Griffin) and other cases involving similar legal issues with the cited insurers may be affected if the supreme court resolves the conflict.
- What happens next?
- The certified conflict may prompt review by the Florida Supreme Court, which can accept jurisdiction to resolve the disagreement between district courts.
- Can this order be reheard or appealed?
- The district court noted the decision is not final until any timely motion for rehearing is resolved; certification itself enables potential review by the Florida Supreme Court.
The above suggestions and answers are AI-generated for informational purposes only. They may contain errors. NoticeRegistry assumes no responsibility for their accuracy. Consult a qualified attorney before relying on them.
Full Filing Text
DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
FOURTH DISTRICT
UNIVERSAL PROPERTY & CASUALTY INSURANCE COMPANY,
Appellant,
v.
JADA GRIFFIN,
Appellee.
No. 4D2024-1332
[April 22, 2026]
Appeal from the Circuit Court for the Fifteenth Judicial Circuit, Palm Beach
County; Gerard J. Curley Jr., Judge; L.T. Case No. 502022CA001699XXXXMB.
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
MAY, J.
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.
CONNER and LOTT, JJ., concur.
* * *
Not final until disposition of timely-filed motion for rehearing.