Serving the Civil Remedy Notice (CRN) to Perfect a First-Party Bad Faith Insurance Claim

In order for an insured under a first-party insurance policy (e.g., property insurance policy) to have a bad faith claim against their insurer, they must first file a Civil Remedy Notice (known as a “CRN”) per Florida statute s. 624.155 identifying the alleged bad faith violation. The CRN gives the insurer sixty days to cure the alleged bad faith violation. In a recent opinion, Apex Roofing and Restoration, LLC A/A/O Derrick v. State Farm Florida Ins. Co., 47 Fla.L.Weekly D1423c (Fla. 5th DCA 2022), the Court looked at two things. First, whether the sixty-day cure period in s. 624.155 is tolled...