Galindo v. Ari Mutual Insurance Co.

BIRCH, Circuit Judge:

These consolidated cases present the issue of whether a supplemental claim on a homeowner’s insurance policy permits the insurance company to investigate the additional claim before appraisal is required under, the policy. The district judges determined that the insurance companies’ investigation of the subsequent claims was a condition precedent to appraisal; consequently, the insureds’ appraisal request was premature. We affirm.

I. BACKGROUND

In the wake of Hurricane Andrew, which devastated Dade County, Florida, on August 24, 1992, numerous residential owners made claims…