Two Florida appellate courts recently affirmed that an insured’s multiple-year delay in reporting property damage violates the obligation of prompt notice to the insurer. In Camacho v. Citizens Prop. Ins. Corp., a Florida appellate court affirmed summary judgment for Citizens Property Insurance Corporation, holding that a nearly three-year delay in reporting hurricane-related property damage to a residence hindered the insurer’s ability to evaluate, investigate, and adjust the claim. 426 So. 3d 1275 (Fla. Dist. Ct. App. 2026).

In Camacho, the insured suffered Hurricane Irma-related damage to his property, but he failed to report the loss to Citizens until almost three years after the storm. Citizens subsequently denied the claim on grounds the reporting delay precluded a timely and adequate evaluation and adjustment of the claim. The insured filed suit, and Citizens moved for summary judgment, arguing the insured could not overcome the presumption of prejudice that arose from the delay in reporting the claim. 

The district court granted Citizens’ motion for summary judgment, which was affirmed on appeal, with the appellate court reasoning the three-year reporting delay “insurmountably stymied the insurer’s ability to evaluate, investigate, and adjust the claim.”

That same month, the same appellate court reversed and remanded a district court ruling, holding that even a two-year delay in reporting property damage violates the insured’s obligation of prompt notice to the insurer. Sec. First Ins. Co. v. Moreno, 427 So. 3d 594 (Fla. Dist. Ct. App. 2026). The insureds in Moreno waited over two years after a hurricane to report damage to their home to their insurer, Security First Insurance Company.

The insureds testified they did not report the claim for over two years because of “personal family issues,” even though they observed the alleged damage when it occurred. After trial, Security appealed the denial of its motions for directed verdict on late notice grounds, and the appellate court reversed. The appellate court noted that, because the insureds knew of property damage for over two years but did not report the damage due to personal issues, the notice was not prompt. The court remanded for a new trial solely on the issue of whether Security was prejudiced by the late notice.

These cases confirm the importance of timeliness in an insured’s reporting of a claim. The obligations that occur post-loss in insurance coverage claims are not simply technicalities. Rather, they are important guidelines that must be followed by the insured to prevent favorable, case-dispositive scenarios for a carrier.