United Property & Casualty Insurance Co. v. Concepcion

United Property and Casualty Insurance Company appeals the trial court’s non-final order granting the insured’s motion to compel appraisal of a claim under a homeowner’s insurance policy. Because there was an issue of fact as to whether the insured complied with his post-loss obligations, the trial court’s failure to conduct an evidentiary hearing constituted error. We therefore reverse and remand.

Jose Concepcion’s property was damaged in October 2004 by Hurricane Wilma. United acknowledged coverage for the loss, and in 2005, tendered approximately $7,000 in payment for damages. In March…