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Florida Fourth DCA rules that Florida law did not require that insurance company notify first named insured when another insured under same motor vehicle policy cancelled policy

On February 10, 2021, in Spielberg v. Progressive Select Insurance Company, No. 4D19-3081, the Florida Fourth DCAaffirmed a summary judgment for the defendant insurance company in a declaratory judgment case, concluding that the defendant insurance company was not required under Florida law to provide notice to the plaintiff, the first named insured under the subject motor vehicle insurance policy, that her son, another named insured, had cancelled the insurance policy. The Fourth DCA ruled that Fla. Stat. 627.728(3)(a), which requires notice to the first named insured prior to the cancellation of a policy, only applies to insurer-initiated policy cancellations.

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