CITIZENS PROPERTY INSURANCE CORPORATION v. Michigan Condominium Association

An insurer appeals from a circuit court order granting the insured’s motion to compel an appraisal before the court re solved the parties’ underlying coverage dispute. The insurer argues that the order conflicts with our holding that a trial court “must resolve all underlying coverage disputes prior to ordering an appraisal.” Sunshine State Ins. Co. v. Corridori, 28 So.3d 129, 131 (Fla. 4th DCA 2010). We agree and reverse.

The insured argues that Corridori is distinguishable because there, the insurer denied coverage before the insured filed suit, whereas here the insurer denied coverage after…