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Florida Appellate Court Confirms Insurer Cannot Waive Residency Requirement in Homeowners Policy

calendar_today November 24, 2025 person Stephanie Roman domain cozen-oconnor

Florida’s Fourth District Court of Appeal recently clarified the enforceability of the “residence-premises” requirement in homeowners’ insurance policies. In Universal Property & Casualty Insurance Company v. Boniface Jean, the appellate court reversed a jury verdict in favor of the homeowner, holding that coverage cannot be created by waiver when the insured does not reside at the covered property.

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