The Eleventh Circuit has found that the lower court did not err in finding coverage for damages that a condominium complex suffered as a result of Hurricane Irma, nor did the court err in only awarding a fraction of the amount sought by the Condominium Association. The case is St. Louis Condominium Association, Inc. v. Rockhill Ins. Co., No. 19-12716 (11th Cir. July 20, 2021).

On September 10, 2017, Hurricane Irma made landfall in South Florida causing damage to a waterfront condo in Miami. St. Louis Condominium Association, Inc. (the Association) tried to recover damages to the property from the insurer, Rockhill Insurance Company (Rockhill). The proof of loss that the Association submitted claimed damages of $16 million. In contrast, Rockhill's inspection determined the damage was "well below" the hurricane deductible, which required that the damage exceed 3 percent of the total value of the insured building, or $945,342. The Association sued.

After the jury trial, the Association received $2.6 million, a fraction of the $16 million it asked for initially. Both parties were unhappy with the result.