Valerie Dondero, of our Miami office, has finally put to rest a 2011 case, with some help from Florida’s updated summary judgment standard. The plaintiff, was the at-fault driver in a 2011 auto accident. His insurer denied coverage for the accident, asserting that it had no duty to defend the insured since he had failed to purchase bodily injury (“BI”) liability coverage. A prior motion for summary judgment was filed on behalf of the insurer in 2015 under the old summary judgment standard.  The court denied the motion at that time based upon the plaintiff’s testimony that he thought he had purchased BI coverage prior to the date of loss. In May of 2021, the Florida Supreme Court updated Florida Rule of Civil Procedure 1.510 governing the review of motions for summary judgment, aligning the rule with its federal rule counterpart and encouraging litigants who had previously filed for summary judgment under the old rule to file renewed motions.  Following a renewed motion for summary judgment, the court granted the insurer’s motion for summary judgment.