People’s Trust Insurance Company notched a key appellate victory on May 7, 2025, when Florida’s Second District Court of Appeal reversed a lower court decision that had favored homeowners John and Lois Abraham. The case reaffirms insurers’ rights to enforce managed repair provisions - an issue of growing significance in Florida’s property insurance market.
The dispute began after the Abrahams filed a claim under their homeowner’s policy for roof damage. People’s Trust accepted coverage and chose to exercise a policy provision that allowed it to repair the damage instead of issuing a cash payout. This “option to repair” clause, standard in the company’s policies, designated Rapid Response Team, LLC (RRT) as the contractor and required the insureds to sign a work authorization and pay their deductible to RRT.
The Abrahams, however, refused to sign the work authorization and did not pay the deductible. They claimed doing so would violate Florida law because RRT held only a general contractor’s license and not a roofing license - despite the fact that the majority of the repairs involved the roof. They also argued that People’s Trust had breached the policy by failing to provide documentation showing that RRT was properly licensed.
People’s Trust sued to enforce the policy terms, but the trial court sided with the Abrahams, finding that signing the work authorization would amount to contracting for illegal work. The court also found that the insurer was required to “cause” the contractor to produce licensure documentation, even though the policy only stated that the insurer would “instruct” RRT to provide it and “may, at [its] option,” assist.
On appeal, the Second District reversed. The court held that the relevant statute - section 489.113, Florida Statutes - does not prohibit a general contractor from managing roofing repairs, as long as the actual roofing work is subcontracted to licensed roofers. That interpretation, the court emphasized, had already been adopted by the Fourth District in People’s Trust Insurance Co. v. Lamolli, a 2022 case involving the same contractor and insurer.
The appellate judges also corrected the trial court’s reading of the policy. They found that People’s Trust had no contractual duty to provide licensure documentation itself, only to instruct RRT to do so. The policy’s language did not support the claim that the insurer must “cause” the contractor to produce the documents.
With no factual disputes in play, the court concluded that the Abrahams had materially breached the policy by refusing to cooperate. Their failure to sign the work authorization and pay the deductible blocked the repair process and justified a judgment in favor of the insurer.
The decision has been sent back to the trial court with instructions to enter judgment for People’s Trust. For insurers operating in Florida, where repair disputes frequently escalate into litigation, the ruling reinforces the validity of managed repair provisions - particularly when policy language is clear and supported by statutory law.
