The case law on this topic is divergent, a trend that will likely continue with different courts applying different interpretations of insurance policies.
The ratings issue has come at a turbulent time in Florida's property-insurance market, as carriers have shed policies and sought large rate increases because of financial losses.
As Florida's property-insurance market has crumbled and home values have soared, many homeowners have been dropped by private insurers and cannot qualify for Citizens coverage because of the $700,000 cap.