Super Green Air Control, LLC a/a/o Karen Roshell v. Universal Property and Casualty Insurance Company

Summary

The Florida First District Court of Appeal held that an insured homeowner’s assignment of benefits and related invoice satisfied the requirements of section 627.7152(2), Florida Statutes (2022). The court reversed the dismissal of Super Green Air Control’s claim against Universal Property and Casualty Insurance Company and remanded for further proceedings.

Holdings

1. The assignment of benefits and related invoice satisfied section 627.7152's statutory requirements and were not invalid or unenforceable.
2. The invoice's descriptions of Protocol and Clearance services were legally sufficient under section 627.7152.
3. The absence of an express number of units did not invalidate the assignment because the record showed no evidence of multiple units at the insured's address and the documents clearly contemplated a single service.

Questions Presented

1. Whether the homeowner's assignment of benefits and related invoice satisfied the written, itemized, per-unit cost-estimate requirements of section 627.7152(2)(a)1.4., Florida Statutes (2022).
2. Whether the assignment and invoice could be construed together in pari materia to determine statutory compliance.
3. Whether the absence of an express number of service units rendered the assignment invalid.

Disposition

reversed_and_remanded