A Nominal Offer can Serve as a “Good Faith” Proposal for Settlement

In a recent property insurance coverage dispute, Citizens Property Insurance Corp. v. Sauerez,  51 Fla.L.Weekly D1687a (Fla. 3d DCA 2026), the insurer served a $100 proposal for settlement. The plaintiff did not accept. The insurer moved for summary judgment which the trial court granted. The insurer moved for its attorney’s fees based on the unaccepted proposal for settlement. The plaintiff claimed the $100 proposal was not made in good faith, which the trial court also agreed. This was reversed on appeal. “We find that the trial court abused its discretion in determining that [the insurer’s] nominal offer was made in bad faith when [plaintiff’s] failure to comply with the insurance policy was a reasonable basis for [the insurer] to offer a nominal settlement amount.” See Saurez, supra.