A Florida appeals court handed Citizens a win that could shut down a popular workaround in property claims disputes.
On June 3, 2026, the Fourth District Court of Appeal ruled that the state's assignment-of-benefits law reaches more than the first transfer of policy benefits. It also reaches the next sale down the chain to a financial buyer.
The case began when a homeowner assigned the benefits of a Citizens policy to a service provider, Quality Assessments & Logistics. The provider then sold its right to payment and its right to sue to Black Diamond Funding Ventures, a firm that buys unpaid invoices from service companies and pursues the outstanding balance. After Citizens did not pay, Black Diamond sued for breach of the policy, relying on the assignment, the purchase agreement, and the service provider's invoice.
The dispute turned on the reach of section 627.7152. Did the law govern only the handoff from homeowner to contractor, or did it also cover the resale to a buyer like Black Diamond?
The court said both. It pointed to the statute's definition of an assignment agreement, which covers any instrument by which post-loss benefits are acquired in any manner, to or from a person providing services to protect, repair, restore, or replace property. The judges described that language as expansive.
Black Diamond's deal fit the definition. The court noted that the purchase agreement called for the insurer to pay Black Diamond directly, gave the firm the right to sue to enforce collection, and ended once Black Diamond received full payment of the purchased invoices. On that basis, the court found the firm had acquired post-loss benefits.
Black Diamond argued the law applies only to transfers from an insured to a service provider, or between service providers, citing an earlier decision called Adjei. The court rejected that reading, finding the case contains no such holding.
The court acknowledged that parts of the statute, including rules on estimates, performance of work, and revised scopes of work, seem aimed at companies actually doing repairs rather than a downstream buyer. Even so, it refused to narrow the definition. An entity that acquires the right to collect and enforce policy benefits is still bound by the statute.
The consequence is direct for carriers. A purchase agreement that qualifies as an assignment agreement but fails the statute's requirements is invalid and unenforceable. Because Black Diamond's agreement did not comply, the firm lacked standing to sue. The court reversed and sent the case back for summary judgment in Citizens' favor.
One note for claims teams: the statute version in play applied from July 1, 2019 to May 25, 2022, and the current version bars assignment agreements on policies issued on or after January 1, 2023.
