( January 11, 2024, 8:40 AM EST) -- MIAMI — A Florida appeals panel held that a lower court properly determined that insureds breached their insurance policy's prompt notice provision and correctly applied the presumption of prejudice in a Hurricane Irma coverage dispute, certifying conflict with Perez v. Citizens Property Insurance Corporation, which concluded that the language in an insurance policy’s “Duties after Loss” provision of “upends the presumption” and placed “the initial burden on” the insurer to show that it was prejudiced....