In Cantens v. Certain Underwriters at Lloyd’s London, No. 3D22-0917 (Fla. 3d DCA Feb. 14, 2024), the Third District aligned itself with the Fourth District, holding that the pre-suit notice requirement for property insurance claims applies retroactively. The pre-suit notice requirement was added in section 627.70152(3)(a), Fla. Stat. (2021), which was effective on July 1, 2021.  The statute says it “applies exclusively to all suits arising under a residential or commercial property insurance policy.”  The Third District found that this language intended for retroactive application to policies issued before July 1, 2021.  The court also ruled that, because the statute was procedural in nature, retroactive application was constitutional.  In so doing, the court certified conflict with the Sixth District.  Circuit courts will be required to follow the precedent in their district, but the argument should still be preserved in the Sixth District. View the opinion here.