Citizens Insurance Appeal Setback on Water Damage Claims Highlights Legal Complexities

Citizens Property Insurance Faces Appeal Setback Due to Incomplete Trial Record

Citizens Property Insurance recently encountered a legal setback in its appeal concerning a water damage claim. The Third District Court of Appeal upheld a lower court's decision, awarding $61,017.51 to Miami-Dade County homeowners, Sandra and Carlos Luis Blanco, due to insufficient evidence presented during the appeal process.

The dispute centered on damage claimed from a water event in the Blanco home on November 16, 2015. Citizens initially denied the claim, citing policy conditions that exclude coverage for long-term water seepage, even when coincidental with a covered event. The policy's anti-concurrent cause clause disallows compensation for losses associated with continuous seepage, irrespective of concurrent covered incidents.

During the trial, Citizens contended that prolonged moisture exposure was the cause, classifying it as an excluded peril. The insurer argued that any accidental discharge was nullified by the anti-concurrent cause clause. Conversely, the Blancos insisted the damage arose from a single, covered incident—a sudden home flood on the specified date, with no evidence of gradual leakage.

Trial and Appeal Challenges

The jury sided with the Blancos. Citizens sought a directed verdict from the trial judge, and upon its denial, they appealed. The appeals court found the insurer had failed to provide a complete trial transcript, notably missing key testimony from Sandra Blanco. Florida law mandates appellate courts interpret evidence favorably towards the trial winner, making the incomplete record a significant hurdle for Citizens.

The appellate judges could not verify whether the trial evidence was definitively one-sided or entailed reasonable debate. This limitation led to siding with the jury's determination, as resolving conflicting evidence typically falls within the jury's purview.

Precedent and Legal Implications

The appeal judgment, delivered on February 4, 2026, noted that Citizens attempted to reference a similar 2020 case, Security First Insurance Co. v. Czelusniak, where policy language led to a verdict favoring the insurer. However, the lack of a complete trial record prevented parallels from influencing the current decision.

Citizens' additional appeal arguments, regarding repair cost admissions and jury instructions, were dismissed. This ruling highlights for claims and underwriting professionals the importance of maintaining comprehensive records in appeals. Even with clear policy clauses, incomplete documentation can weaken a carrier's position. Moreover, the case emphasizes the complexities surrounding anti-concurrent cause clauses in property claims, where damage attribution often hinges on expert testimony—areas where juries typically make final determinations.