In People’s Trust Insurance Company v. Hernandez, 4D2024-3274 (Fla. 4th DCA March 26, 2025), the Fourth District held that a party seeking to reject a non-binding arbitration award and proceed to trial must strictly comply with Rule 1.820(h)’s requirement of filing “a notice of rejection of the arbitration award and request for trial in the same document.” Fla. R. Civ. P. 1820(h) (emphasis added). After the arbitrator returned its decision on the plaintiff’s first-party property damage claim, the plaintiff filed a “Motion for Trial De Novo,” which requested a trial de novo by the circuit court, but did not include a “notice of rejection of the arbitration decision,” as required by the amendments to rule 1.820(h) that became effective on July 1, 2024. The trial court denied the insurer’s motion to enforce the arbitration decision, but the Fourth District reversed, agreeing with the insurer that the plaintiff’s motion was deficient because it did not expressly reject the arbitration decision. The court rejected the plaintiff’s argument that its motion substantially complied with rule 1.820(h), relying on the rule’s requirement that a party must file the notice of rejection and request for trial “in the same document,” and the provision that “[n]o action or inaction by any party, other than the filing of the notice, will be deemed a rejection of the arbitration decision.” The court refused to resurrect the “some notice” standard established in Nicholson-Kenny Capital Management, Inc. v. Steinberg, 932 So. 2d 321 (Fla. 4th DCA 2006), observing that doing so “would erroneously reopen a door which we had correctly closed in Lawnwood Medical Center, Inc. v. Rouse, 394 So. 3d 51 (Fla. 4th DCA 2024).” This decision confirms that Rule 1.820(h) will be strictly enforced, and parties must take care to comply with its requirements if they decide to reject a nonbinding arbitration award and proceed to trial. View the opinion here.