In Florida Insurance Guarantee Association v. Feijoo, 49 Fla. L. Weekly D801 (Fla. 3d DCA 2024), Caryn Bellus and Barbara Fox obtained a reversal of a summary judgment. Plaintiff amended the complaint to name FIGA after Windhaven Insurance Company was declared insolvent. After FIGA tendered full payment, Plaintiff sought summary judgment under its declaratory judgment claim for improper policy cancellation, but asserted, outside the pleading, that it was entitled to a declaration regarding the policy’s validity and effectiveness on the date of loss. The appellate court found the two claims to be substantially different and held summary judgment was improperly entered on a claim that was never pled.