In Spielberg v. Progressive Select Ins. Co., No. 4D19-3081 (Fla. 4th DCA Feb. 10, 2021), the Fourth DCA held that an auto insurer did not have to provide certain statutorily-prescribed policy cancellation notice requirements when the cancellation was requested by a named insured—as opposed to being initiated by the insurer itself.  Unbeknownst to Plaintiff, a named insured on the auto policy and who was involved in an auto accident four days after her son- also a named insured on the policy – requested the insurer cancel the policy.  Plaintiff argued that she did not receive proper notice of cancellation as required under Florida statutes. The Fourth DCA disagreed, explaining that although Plaintiff’s auto policy was of the type covered under the statutory provisions regarding cancellation notice requirements, the notice requirements had not been triggered since the request for cancellation was not one of the insurer-initiated reasons for cancellation laid out in the statutes. Accordingly, summary judgment in favor of Progressive was affirmed.