Florida homeowners may now have stronger footing when fighting for fair insurance payments for property damage. In a significant new decision, Florida's Second District Court of Appeal (2d DCA) ruled that labor costs and other necessary repair expenses are part of a property owner's actual cash value (ACV) claim—not just the raw cost of damaged materials.  You can read more about the difference between replacement cost value (RCV) and ACV here.

The case—Greenaker v. Universal Property & Casualty Insurance Company—addresses a common issue in Florida property insurance disputes: how insurers calculate ACV payments after a loss.

Many homeowners are surprised to learn that insurers often make an initial ACV payment before paying full replacement cost benefits. In practice, this initial payment can make a major difference in whether a homeowner can begin repairs at all.

What Was the Dispute in Greenaker About?

The homeowners in Greenaker suffered storm damage and submitted repair estimates that included both material costs and labor expenses necessary to complete repairs. The insurance company argued that labor costs should not count toward ACV because the work had not yet been completed.

The trial court agreed with the insurer and excluded the homeowners' damages evidence, ultimately entering judgment against them before trial.

Thankfully, Florida's 2d DCA reversed that decision.

The 2d DCA's Key Holding: ACV Includes Labor Costs

The appellate court made clear that ACV is not limited solely to the value of damaged physical materials. Instead, ACV can include labor, overhead, profit, and other repair-related costs that a homeowner is reasonably likely to incur.

The court emphasized that the difference between ACV and RCV (actual cash versus replacement cost value) is generally depreciation—not whether labor costs are included at all.

In other words:

• RCV typically reflects the full, undepreciated cost of repairs.
• ACV reflects those same repair costs after depreciation is applied.

The court rejected the insurer's attempt to separate material costs from labor costs in calculating ACV.

Read the full Greenaker opinion here.

Why This Matters for Florida Homeowners

This ruling could have important real-world consequences for policyholders across Florida.

When insurers artificially reduce ACV payments by excluding labor or other necessary repair costs, homeowners may receive far less money upfront than they actually need to begin restoring their property.

For many families, that creates a serious financial burden after a storm or other covered loss.

The Greenaker decision reinforces the principle that insurance policies should be interpreted according to their actual language—not rewritten to narrow coverage after a loss occurs.

Understanding Your Rights After Property Damage

Insurance claims involving ACV, depreciation, replacement cost, matching issues, and policy interpretation can quickly become complex.  If your insurer underpaid your claim, excluded portions of necessary repairs, or disputed the scope of your damages, it is important to understand your rights under Florida law.

At Taylor, Warren, Weidner, Hancock & Barnes, P.A., our experienced insurance dispute attorneys continue to monitor important developments in Florida insurance law and advocate for policyholders facing difficult claim disputes.  If you have questions about a denied or underpaid property insurance claim, our team is available to help review your situation.