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Insurance
12 min read
Areas of Expertise :
Insurance, Property Insurance, Property Damage, Cause And Origin, Breach Of Contract
Published Date:
Last Modified Date:
Jurisdiction:
Federal. Eleventh Circuit
Court:
Mama Jo’s Inc., doing business as Berries, operated a restaurant on SW 27th Avenue in Miami, Florida, where roadway construction took place nearby from December 2013 through June 2015. Dust and debris from the construction entered the restaurant, and Berries performed daily cleaning while remaining open throughout the work. Berries submitted a claim to Sparta Insurance Company for cleaning and painting costs, along with alleged business income losses tied to reduced customer traffic. Sparta denied the claim in January 2017, stating that the claimed conditions did not show direct physical loss or damage under the policy.
Berries sued Sparta for breach of contract, and the dispute became an insurance coverage case centered on whether construction dust, debris, cleaning costs, and alleged business income losses triggered policy benefits. During litigation, Berries later added claimed damages involving the awning and retractable roof systems, HVAC repairs, and audio and lighting systems. The district court excluded Berries’ causation experts, granted summary judgment for Sparta, and found that cleaning dust and debris did not amount to direct physical loss under the policy. The Eleventh Circuit affirmed on August 18, 2020, and later proceedings addressed Sparta’s recovery of attorneys’ fees, costs, appellate fees, and post-judgment collection issues.
Mama Jo’s Inc., doing business as Berries, operated a restaurant on SW 27th Avenue in Miami while roadway construction occurred nearby. During the work, dust and debris entered the restaurant, and Berries used daily cleaning methods such as dust pans, hoses, rags, towels, and blowers. The restaurant remained open every day, although customer traffic declined during the roadwork.
Sparta Insurance Company insured Berries under an all-risk commercial property policy during this period. The policy included Building and Personal Property coverage and Business Income coverage tied to direct physical loss of or damage to covered property. Those policy terms later became central to the insurance coverage dispute because Berries had to connect its claimed losses to covered damage during the policy period.
Berries submitted a claim to Sparta stating that construction dust and debris from the roadway work caused loss at the restaurant. Sparta assigned insurance adjuster Corey Buford to review the claim, while Berries used public adjuster Robert Inguanzo of Epic Group Public Adjusters. The claim initially focused on cleaning, painting, and alleged business income loss.
In March 2015, Inguanzo prepared an estimate of $16,275.58 to clean and paint the restaurant. In April 2015, Berries submitted a sworn proof of loss for a building claim calculated at $13,775.58 after a deductible, along with a business income claim of $292,550.84. Berries contended that its 2014 sales were lower than expected when compared with earlier growth patterns.
Sparta denied the claim, stating that it was not covered under the policy. The denial letter questioned whether the proof of loss showed physical damage and whether direct physical loss had occurred. Sparta also relied on the Business Income form, which required a necessary suspension of operations caused by direct physical loss of or damage to property.
Berries filed suit in Florida state court after Sparta denied the claim, and Sparta removed the case to the United States District Court for the Southern District of Florida. In its initial disclosures, Berries sought the same categories presented before suit: cleaning and painting costs, plus lower-than-expected 2014 sales. The case moved from claim adjustment into federal litigation over policy language, causation, and proof of covered property damage.
Berries served amended interrogatory answers identifying newly claimed property damage categories totaling $319,688.57. These categories included replacement of the awning and retractable roof systems, HVAC repairs, and replacement of audio and lighting systems. The added categories changed the proof burden because Berries had to connect those later-claimed property losses to construction dust and debris from Sparta’s policy period.
Sparta moved to preclude the opinions of Berries’ proposed plaintiff-side causation experts: Alex Posada for the audio and lighting systems, Christopher Thompson for the awning and retractable roof systems, and Alfredo Brizuela for engineering and cause-of-loss opinions. Their proposed opinions related to the later-added property damage claims that Berries alleged were connected to construction dust and debris during Sparta’s policy period. The court later excluded the opinions after finding the causation methods unreliable or unsupported, which left Berries without sufficient expert evidence to connect the disputed property systems to the roadwork.
The district court granted Sparta’s Daubert motion and summary judgment motion. It found that Berries could not recover the initial cleaning-related damages because cleaning dust and debris, without property damage, did not amount to direct physical loss. It also found that Berries could not recover the later-added equipment and system damages because the excluded expert opinions left Berries without sufficient causation proof.
The Eleventh Circuit affirmed the district court’s rulings in favor of Sparta. The appellate court agreed that the district court did not abuse its discretion in excluding the proposed expert opinions and that Berries failed to establish covered direct physical loss or damage. The ruling resolved the main merits dispute against Berries and left Sparta as the prevailing party.
After the merits ruling, Sparta sought trial-level attorneys’ fees and costs based on Florida’s offer of judgment statute and its earlier $10,000 settlement offer. The report concluded that Sparta’s offer had a reasonable foundation and that Berries did not prove the offer was made in bad faith. The report recommended reducing the requested amounts but awarding Sparta reasonable fees and costs.
The district court adopted the fee and cost recommendation. Sparta received $10,877.64 in costs and $95,808.50 in attorneys’ fees, for a total award of $106,686.14. This order added a monetary recovery for Sparta after its summary judgment victory.
A later report addressed Sparta’s request for appellate attorneys’ fees and entry of judgment. The report noted that Berries had petitioned the Supreme Court of the United States for review of the Eleventh Circuit’s decision affirming summary judgment, and that the petition had been denied. It recommended granting Sparta’s request for $54,944.50 in appellate attorneys’ fees and entering judgment for the earlier $106,686.14 fee-and-cost award.
After the fee and appellate-fee awards, the district court entered final judgment in favor of Sparta for $106,686.14 in trial fees and costs and $54,944.50 in appellate fees, totaling $161,630.64. Sparta assigned the judgment to Casa Financial Holdings, LLC, and garnishment proceedings followed involving BankUnited, N.A. BankUnited retained funds under a writ of garnishment, and later disputes arose over disbursement, satisfaction of judgment, interest, costs, and related attorney’s fees.
The district court adopted the report and recommendation on BankUnited’s verified motion for attorney’s fees in the garnishment proceedings. BankUnited was awarded $8,680.00 for recoverable fees tied to the post-judgment garnishment dispute, with reductions for unsupported, duplicative, or non-compensable work. By this stage, the merits of the case had already been resolved through summary judgment for Sparta, appellate affirmance, denial of further review, and fee awards for Sparta. The August 21, 2023 order addressed a later collection-related issue rather than the underlying insurance coverage dispute.
United States District Court for the Southern District of Florida
Case Name:
Mama Jo’s Inc. d/b/a Berries v. Sparta Insurance Company
Insurance Coverage
Insurance Claims
Proof Of Loss
Causation Analysis
Indoor Air Quality
Construction Damages
Commercial Construction
Restaurant Economics
Mama Jo’s Inc., doing business as Berries, operated a restaurant on SW 27th Avenue in Miami, Florida, where roadway construction took place nearby from December 2013 through June 2015. Dust and debris from the construction entered the restaurant, and Berries performed daily cleaning while remaining open throughout the work. Berries submitted a claim to Sparta Insurance Company for cleaning and painting costs, along with alleged business income losses tied to reduced customer traffic. Sparta denied the claim in January 2017, stating that the claimed conditions did not show direct physical loss or damage under the policy.
Berries sued Sparta for breach of contract, and the dispute became an insurance coverage case centered on whether construction dust, debris, cleaning costs, and alleged business income losses triggered policy benefits. During litigation, Berries later added claimed damages involving the awning and retractable roof systems, HVAC repairs, and audio and lighting systems. The district court excluded Berries’ causation experts, granted summary judgment for Sparta, and found that cleaning dust and debris did not amount to direct physical loss under the policy. The Eleventh Circuit affirmed on August 18, 2020, and later proceedings addressed Sparta’s recovery of attorneys’ fees, costs, appellate fees, and post-judgment collection issues.
Mama Jo’s Inc., doing business as Berries, operated a restaurant on SW 27th Avenue in Miami while roadway construction occurred nearby. During the work, dust and debris entered the restaurant, and Berries used daily cleaning methods such as dust pans, hoses, rags, towels, and blowers. The restaurant remained open every day, although customer traffic declined during the roadwork.
Sparta Insurance Company insured Berries under an all-risk commercial property policy during this period. The policy included Building and Personal Property coverage and Business Income coverage tied to direct physical loss of or damage to covered property. Those policy terms later became central to the insurance coverage dispute because Berries had to connect its claimed losses to covered damage during the policy period.
Berries submitted a claim to Sparta stating that construction dust and debris from the roadway work caused loss at the restaurant. Sparta assigned insurance adjuster Corey Buford to review the claim, while Berries used public adjuster Robert Inguanzo of Epic Group Public Adjusters. The claim initially focused on cleaning, painting, and alleged business income loss.
In March 2015, Inguanzo prepared an estimate of $16,275.58 to clean and paint the restaurant. In April 2015, Berries submitted a sworn proof of loss for a building claim calculated at $13,775.58 after a deductible, along with a business income claim of $292,550.84. Berries contended that its 2014 sales were lower than expected when compared with earlier growth patterns.
Sparta denied the claim, stating that it was not covered under the policy. The denial letter questioned whether the proof of loss showed physical damage and whether direct physical loss had occurred. Sparta also relied on the Business Income form, which required a necessary suspension of operations caused by direct physical loss of or damage to property.
Berries filed suit in Florida state court after Sparta denied the claim, and Sparta removed the case to the United States District Court for the Southern District of Florida. In its initial disclosures, Berries sought the same categories presented before suit: cleaning and painting costs, plus lower-than-expected 2014 sales. The case moved from claim adjustment into federal litigation over policy language, causation, and proof of covered property damage.
Berries served amended interrogatory answers identifying newly claimed property damage categories totaling $319,688.57. These categories included replacement of the awning and retractable roof systems, HVAC repairs, and replacement of audio and lighting systems. The added categories changed the proof burden because Berries had to connect those later-claimed property losses to construction dust and debris from Sparta’s policy period.
Sparta moved to preclude the opinions of Berries’ proposed plaintiff-side causation experts: Alex Posada for the audio and lighting systems, Christopher Thompson for the awning and retractable roof systems, and Alfredo Brizuela for engineering and cause-of-loss opinions. Their proposed opinions related to the later-added property damage claims that Berries alleged were connected to construction dust and debris during Sparta’s policy period. The court later excluded the opinions after finding the causation methods unreliable or unsupported, which left Berries without sufficient expert evidence to connect the disputed property systems to the roadwork.
The district court granted Sparta’s Daubert motion and summary judgment motion. It found that Berries could not recover the initial cleaning-related damages because cleaning dust and debris, without property damage, did not amount to direct physical loss. It also found that Berries could not recover the later-added equipment and system damages because the excluded expert opinions left Berries without sufficient causation proof.
The Eleventh Circuit affirmed the district court’s rulings in favor of Sparta. The appellate court agreed that the district court did not abuse its discretion in excluding the proposed expert opinions and that Berries failed to establish covered direct physical loss or damage. The ruling resolved the main merits dispute against Berries and left Sparta as the prevailing party.
After the merits ruling, Sparta sought trial-level attorneys’ fees and costs based on Florida’s offer of judgment statute and its earlier $10,000 settlement offer. The report concluded that Sparta’s offer had a reasonable foundation and that Berries did not prove the offer was made in bad faith. The report recommended reducing the requested amounts but awarding Sparta reasonable fees and costs.
The district court adopted the fee and cost recommendation. Sparta received $10,877.64 in costs and $95,808.50 in attorneys’ fees, for a total award of $106,686.14. This order added a monetary recovery for Sparta after its summary judgment victory.
A later report addressed Sparta’s request for appellate attorneys’ fees and entry of judgment. The report noted that Berries had petitioned the Supreme Court of the United States for review of the Eleventh Circuit’s decision affirming summary judgment, and that the petition had been denied. It recommended granting Sparta’s request for $54,944.50 in appellate attorneys’ fees and entering judgment for the earlier $106,686.14 fee-and-cost award.
After the fee and appellate-fee awards, the district court entered final judgment in favor of Sparta for $106,686.14 in trial fees and costs and $54,944.50 in appellate fees, totaling $161,630.64. Sparta assigned the judgment to Casa Financial Holdings, LLC, and garnishment proceedings followed involving BankUnited, N.A. BankUnited retained funds under a writ of garnishment, and later disputes arose over disbursement, satisfaction of judgment, interest, costs, and related attorney’s fees.
The district court adopted the report and recommendation on BankUnited’s verified motion for attorney’s fees in the garnishment proceedings. BankUnited was awarded $8,680.00 for recoverable fees tied to the post-judgment garnishment dispute, with reductions for unsupported, duplicative, or non-compensable work. By this stage, the merits of the case had already been resolved through summary judgment for Sparta, appellate affirmance, denial of further review, and fee awards for Sparta. The August 21, 2023 order addressed a later collection-related issue rather than the underlying insurance coverage dispute.
Audio and Lighting Systems Expert Witness (Plaintiff)
Alex Posada was publicly disclosed as one of Berries’ plaintiff-side experts. His proposed opinions concerned the restaurant’s audio and lighting systems, which Berries later claimed were damaged by construction dust and debris. The court reviewed his proposed method and excluded his opinions after finding the causation analysis unreliable. Because of that ruling, his opinions did not support Berries’ effort to prove that the claimed audio and lighting damage was tied to the roadway construction during Sparta’s policy period.
Awning and Retractable Roofing Systems Expert Witness (Plaintiff)
Christopher Thompson was publicly disclosed as one of Berries’ plaintiff-side experts. His proposed opinions addressed the restaurant’s awning and retractable roof systems, which Berries later included in its claimed damages. The court excluded his opinions after finding that his method did not reliably connect the claimed condition of those systems to construction dust and debris during the relevant policy period. His exclusion contributed to the court’s conclusion that Berries lacked sufficient causation proof for the later-added property damage claims.
Engineering and Cause-of-Loss Expert Witness (Plaintiff)
Alfredo Brizuela was publicly disclosed as one of Berries’ plaintiff-side experts. His proposed opinions involved engineering and the cause and origin of the claimed loss. The court excluded his causation opinions after finding that they did not rest on a reliable method for linking the claimed damage to the roadway construction during Sparta’s policy period. After this ruling, Berries could not use his opinions to establish causation for the disputed property systems.
Property Damage Expert Witness
A property damage expert witness is often engaged in disputes involving alleged building damage, repair scope, cleaning costs, and claimed loss to physical components. In a restaurant property claim involving dust or debris, this expert may review site conditions, maintenance records, photographs, repair estimates, and the difference between cleaning needs and physical damage. This role is relevant when the dispute turns on whether the claimed condition amounts to direct physical loss or damage.
Insurance Coverage Expert Witness
An insurance coverage expert witness is often engaged when parties dispute claim handling, policy wording, coverage positions, proof-of-loss materials, and the relationship between claimed damage and policy requirements. In property cases, this expert may explain common claim-review practices, policy forms, adjustment steps, and the documentation often considered when evaluating a claim.
Anchor the Claim to Policy Language Early
Attorneys should connect each claimed loss to the exact policy requirement from the beginning of the case. In Mama Jo’s, the dispute turned on whether dust, debris, cleaning costs, and business income losses showed direct physical loss of or damage to covered property. A strong insurance coverage strategy should separate cleaning-related expenses from physical alteration, repair, or replacement claims before discovery closes.
Build Causation Evidence Before Expanding Damages
When a plaintiff adds new damage categories, the causation proof must be reliable, timely, and tied to the policy period. Berries later claimed damages involving the awning and retractable roof systems, HVAC repairs, and audio and lighting systems, but the court excluded the proposed causation opinions. Attorneys should make sure each added category has a clear evidentiary path linking the claimed condition to the alleged covered cause.
Treat Expert Methodology as a Case-Defining Issue
The exclusion of Berries’ proposed causation experts became central to the summary judgment ruling. In property damage and insurance coverage disputes, expert opinions should be supported by a reliable method, relevant inspection work, and a defensible link between the event and the claimed damage. Unsupported or weak causation analysis can leave a party unable to prove a required element of the claim.
Preserve Business Income Claims with Operational Proof
Business income claims require more than showing that revenue declined during a disruption. In this case, the restaurant remained open every day, and the policy required a necessary suspension of operations caused by direct physical loss or damage. Attorneys handling similar claims should document operational limits, restoration periods, lost sales calculations, and the connection between the claimed income loss and covered property damage.
Evaluate Settlement Offers and Fee Exposure Carefully
Sparta’s $10,000 offer of judgment later became important in the fee dispute after summary judgment was entered in its favor. The court found that Sparta had a reasonable basis for the offer and awarded reduced attorneys’ fees and costs. Attorneys should assess offer-of-judgment strategy carefully because post-judgment fee exposure can become a major part of the final case outcome.
Mama Jo’s v. Sparta Insurance Company shows how a property claim can turn on the difference between cleaning-related conditions and covered direct physical loss or damage. Berries alleged that roadway construction dust and debris entered its Miami restaurant, causing cleaning costs, business income losses, and later-claimed damage to restaurant systems, but the district court found that cleaning dust and debris did not trigger coverage under the policy. The court also excluded Berries’ proposed causation experts, leaving the later-added damage claims without sufficient proof, and the Eleventh Circuit affirmed summary judgment for Sparta. The case remains useful for attorneys handling insurance coverage disputes because it shows the need to tie each claimed loss to policy language, reliable causation evidence, business income requirements, and the relevant policy period before the case reaches summary judgment.
What was the main dispute in Mama Jo’s v. Sparta Insurance Company?
The case centered on whether dust and debris from nearby roadway construction caused covered property damage at Berries, a Miami restaurant operated by Mama Jo’s Inc. Sparta denied the claim, and Berries sued for breach of contract after seeking cleaning costs, business income losses, and later-added property damage amounts.
Why did Sparta deny Berries’ property claim?
Sparta denied the claim after concluding that the submitted materials did not show covered direct physical loss or damage under the policy. The insurer also relied on the Business Income form, which required a necessary suspension of operations caused by direct physical loss of or damage to property.
Did the restaurant close during the road construction?
No. Berries remained open every day during the roadway construction period, even though customer traffic declined. This fact mattered because the business income claim depended on policy language requiring a covered property loss and a necessary suspension of operations during the period of restoration.
What did the court decide about dust, debris, and cleaning costs?
The district court found that cleaning dust and debris, without covered property damage, did not amount to direct physical loss under the policy. That finding was central to the court’s ruling against Berries on the initial cleaning-related claim.
What happened to Berries’ later-added damage claims?
Berries later claimed damage involving the awning and retractable roof systems, HVAC repairs, and audio and lighting systems. The court found that Berries lacked reliable causation evidence connecting those claimed damages to construction dust and debris during Sparta’s policy period.
Audio and Lighting Systems Expert Witness (Plaintiff)
Alex Posada was publicly disclosed as one of Berries’ plaintiff-side experts. His proposed opinions concerned the restaurant’s audio and lighting systems, which Berries later claimed were damaged by construction dust and debris. The court reviewed his proposed method and excluded his opinions after finding the causation analysis unreliable. Because of that ruling, his opinions did not support Berries’ effort to prove that the claimed audio and lighting damage was tied to the roadway construction during Sparta’s policy period.
Awning and Retractable Roofing Systems Expert Witness (Plaintiff)
Christopher Thompson was publicly disclosed as one of Berries’ plaintiff-side experts. His proposed opinions addressed the restaurant’s awning and retractable roof systems, which Berries later included in its claimed damages. The court excluded his opinions after finding that his method did not reliably connect the claimed condition of those systems to construction dust and debris during the relevant policy period. His exclusion contributed to the court’s conclusion that Berries lacked sufficient causation proof for the later-added property damage claims.
Engineering and Cause-of-Loss Expert Witness (Plaintiff)
Alfredo Brizuela was publicly disclosed as one of Berries’ plaintiff-side experts. His proposed opinions involved engineering and the cause and origin of the claimed loss. The court excluded his causation opinions after finding that they did not rest on a reliable method for linking the claimed damage to the roadway construction during Sparta’s policy period. After this ruling, Berries could not use his opinions to establish causation for the disputed property systems.
Property Damage Expert Witness
A property damage expert witness is often engaged in disputes involving alleged building damage, repair scope, cleaning costs, and claimed loss to physical components. In a restaurant property claim involving dust or debris, this expert may review site conditions, maintenance records, photographs, repair estimates, and the difference between cleaning needs and physical damage. This role is relevant when the dispute turns on whether the claimed condition amounts to direct physical loss or damage.
Insurance Coverage Expert Witness
An insurance coverage expert witness is often engaged when parties dispute claim handling, policy wording, coverage positions, proof-of-loss materials, and the relationship between claimed damage and policy requirements. In property cases, this expert may explain common claim-review practices, policy forms, adjustment steps, and the documentation often considered when evaluating a claim.
Anchor the Claim to Policy Language Early
Attorneys should connect each claimed loss to the exact policy requirement from the beginning of the case. In Mama Jo’s, the dispute turned on whether dust, debris, cleaning costs, and business income losses showed direct physical loss of or damage to covered property. A strong insurance coverage strategy should separate cleaning-related expenses from physical alteration, repair, or replacement claims before discovery closes.
Build Causation Evidence Before Expanding Damages
When a plaintiff adds new damage categories, the causation proof must be reliable, timely, and tied to the policy period. Berries later claimed damages involving the awning and retractable roof systems, HVAC repairs, and audio and lighting systems, but the court excluded the proposed causation opinions. Attorneys should make sure each added category has a clear evidentiary path linking the claimed condition to the alleged covered cause.
Treat Expert Methodology as a Case-Defining Issue
The exclusion of Berries’ proposed causation experts became central to the summary judgment ruling. In property damage and insurance coverage disputes, expert opinions should be supported by a reliable method, relevant inspection work, and a defensible link between the event and the claimed damage. Unsupported or weak causation analysis can leave a party unable to prove a required element of the claim.
Preserve Business Income Claims with Operational Proof
Business income claims require more than showing that revenue declined during a disruption. In this case, the restaurant remained open every day, and the policy required a necessary suspension of operations caused by direct physical loss or damage. Attorneys handling similar claims should document operational limits, restoration periods, lost sales calculations, and the connection between the claimed income loss and covered property damage.
Evaluate Settlement Offers and Fee Exposure Carefully
Sparta’s $10,000 offer of judgment later became important in the fee dispute after summary judgment was entered in its favor. The court found that Sparta had a reasonable basis for the offer and awarded reduced attorneys’ fees and costs. Attorneys should assess offer-of-judgment strategy carefully because post-judgment fee exposure can become a major part of the final case outcome.
Mama Jo’s v. Sparta Insurance Company shows how a property claim can turn on the difference between cleaning-related conditions and covered direct physical loss or damage. Berries alleged that roadway construction dust and debris entered its Miami restaurant, causing cleaning costs, business income losses, and later-claimed damage to restaurant systems, but the district court found that cleaning dust and debris did not trigger coverage under the policy. The court also excluded Berries’ proposed causation experts, leaving the later-added damage claims without sufficient proof, and the Eleventh Circuit affirmed summary judgment for Sparta. The case remains useful for attorneys handling insurance coverage disputes because it shows the need to tie each claimed loss to policy language, reliable causation evidence, business income requirements, and the relevant policy period before the case reaches summary judgment.
What was the main dispute in Mama Jo’s v. Sparta Insurance Company?
The case centered on whether dust and debris from nearby roadway construction caused covered property damage at Berries, a Miami restaurant operated by Mama Jo’s Inc. Sparta denied the claim, and Berries sued for breach of contract after seeking cleaning costs, business income losses, and later-added property damage amounts.
Why did Sparta deny Berries’ property claim?
Sparta denied the claim after concluding that the submitted materials did not show covered direct physical loss or damage under the policy. The insurer also relied on the Business Income form, which required a necessary suspension of operations caused by direct physical loss of or damage to property.
Did the restaurant close during the road construction?
No. Berries remained open every day during the roadway construction period, even though customer traffic declined. This fact mattered because the business income claim depended on policy language requiring a covered property loss and a necessary suspension of operations during the period of restoration.
What did the court decide about dust, debris, and cleaning costs?
The district court found that cleaning dust and debris, without covered property damage, did not amount to direct physical loss under the policy. That finding was central to the court’s ruling against Berries on the initial cleaning-related claim.
What happened to Berries’ later-added damage claims?
Berries later claimed damage involving the awning and retractable roof systems, HVAC repairs, and audio and lighting systems. The court found that Berries lacked reliable causation evidence connecting those claimed damages to construction dust and debris during Sparta’s policy period.
What was the final outcome of the case?
The district court granted summary judgment for Sparta, and the Eleventh Circuit affirmed on August 18, 2020. Later proceedings resulted in fee and cost awards tied to Sparta’s prevailing position, followed by post-judgment collection proceedings involving the fee judgment.
Insurance Coverage
Insurance Claims
Proof Of Loss
Causation Analysis
Indoor Air Quality
Construction Damages
Commercial Construction
Restaurant Economics
Insurance
Actuarial, +4
Insurance
Insurance, +2
Insurance
What was the final outcome of the case?
The district court granted summary judgment for Sparta, and the Eleventh Circuit affirmed on August 18, 2020. Later proceedings resulted in fee and cost awards tied to Sparta’s prevailing position, followed by post-judgment collection proceedings involving the fee judgment.