This is a court’s written decision. The judges had the claim file in front of them, and where they quote the insurer’s denial language, that quotation is part of the official record of the case.
Everything quoted below is read off that document. The reading of what it means for each side is ours, and it is marked as such.
| Case | Goldberg v. Universal Property & Casualty Insurance Company |
|---|---|
| Court | Florida Fourth District Court of Appeal |
| Citation | No. 4D19-3202 |
| Decided | September 9, 2020 |
| Who is involved | A condominium owner and Universal Property & Casualty. |
| What happened | Universal paid the dwelling loss and refused the personal property loss on a wind-driven-rain theory. Summary judgment was affirmed in part and reversed in part. |
| Where | Florida condominium |
| When | Hurricane Irma, 2017. Adjuster inspected October 14, 2017. |
| Why it came out that way | Universal's corporate representative conceded the company had not relied on any causation expert, and the trial court had granted judgment on a ground about supplemental claims rather than coverage. |
| The holding | Affirmed in part, reversed in part, and remanded. |
Our reading of the document above, not the court's words.
For the insurance company
A photo caption did the coverage work here. Two words on an adjuster's photograph, no coverage under the policy, became the company's position on the entire contents claim.
For the homeowner
The concession is the story. Universal's own representative agreed the company had not relied on any causation expert, which left a coverage denial resting on a field adjuster's note.
- 1 Request the adjuster's photographs and their captions, not just the estimate. Captions carry coverage decisions.
- 2 Ask directly whether the carrier retained a causation expert and, if so, for the report.
- 3 Watch how depreciation is applied: replacement cost, minus depreciation, minus deductible, is where the payment shrinks.
Goldberg v. Universal Prop. & Cas. Ins. Co., 302 So. 3d 919 (Fla. 4th DCA Sept. 9, 2020) Read the document ↗
Case summaries are drafted from the document and have not been reviewed by counsel; verify against the current docket before relying on any of it. Not legal advice; consult an attorney about your specific claim.
Two letters in one claim file, running the two quiet levers this library tracks. The contents position: personal property damaged by wind-driven rain, no coverage, no storm-created opening. The dwelling position: paid, minus depreciation “recoverable as work is performed and expenses are incurred,” the holdback that pays only those who spend first and prove it.
The Fourth DCA split the difference in a way that teaches both rules. The dwelling underpayment stood because the homeowner never filed the supplemental claim the statute makes a precondition; procedure beat merit. The contents denial reversed, on the doctrine that a carrier who denies a claim outright waives the policy conditions it would otherwise hide behind; a total no forfeits the fine print. Read together: answer a partial payment with the supplemental process, answer a total denial with the waiver rule, and never confuse which letter you are holding.
Goldberg v. Universal Prop. & Cas. Ins. Co., 302 So. 3d 919 (Fla. 4th DCA Sept. 9, 2020) · public record ↗
Quotes are verbatim from the cited public record. Case status and statute summaries drafted August 2026; verify against the current docket and statute. Not legal advice; consult an attorney about your specific claim.
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