Florida Appeals Court Backs Insurer’s Right to Enforce Repair Option in Homeowner Dispute

In a significant win for Florida property insurers, the Second District Court of Appeal reversed a lower court ruling on May 7, 2025, siding with People’s Trust Insurance Company in a dispute over its right to enforce a managed repair provision. The case involved homeowners John and Lois Abraham, who refused to sign a work authorization and pay a deductible after People’s Trust elected to repair roof damage through its preferred contractor, Rapid Response Team, LLC.

The Abrahams claimed the contractor lacked a proper roofing license and argued that signing the authorization would amount to contracting for illegal work. A trial court agreed, stating that People’s Trust had also breached the policy by not ensuring licensure documentation was provided. However, the appellate court disagreed, citing a 2022 precedent and clarifying that general contractors may manage roofing repairs when licensed subcontractors perform the work.

The appellate judges further clarified the insurer’s obligations under the policy, finding that People’s Trust had fulfilled its duty by instructing the contractor to provide documentation. The policy’s language did not impose a duty to ensure or ‘cause’ the contractor to produce proof of licensing.

Ultimately, the court concluded the Abrahams breached their contract by not cooperating, which justified judgment in favor of the insurer. The decision provides strong precedent supporting insurers’ use of managed repair options, particularly when policy language is unambiguous and supported by Florida law.