October 20, 2025

Appeals Court Upholds Actual Cash Value Claim Payout – LMA Newsletter

Florida’s First District Court of Appeal issued an important opinion regarding Actual Cash Value/Replacement Cost Value (ACV/RCV) in property insurance policies.

In Bailetti v. Universal, the appellate court confirmed the final judgment in favor of Universal.  Universal paid based on its ACV estimate; the insured did not challenge the ACV payment or present a competing ACV estimate prior to suit.  On the eve of trial, the insureds’ expert submitted an estimate that was prepared in 2023 – three years after Hurricane Sally – and did not have a total estimate amount.  The estimate was not provided until the eve of trial.

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