09/06/2026
CITIZENS PROPERTY INSURANCE CORPORATION:
FLORIDA DESERVES MORE THAN A DISPOSITION CODE.
FLORIDA DESERVES THE TRUTH.
I started looking into the Citizens Property Insurance Corporation and Division of Administrative Hearings, DOAH, dispute-resolution system because something did not sit right with me.
The deeper I look, the more questions I have.
And now I believe Florida needs something much larger than another argument between the insurance industry and policyholder advocates.
Florida needs a comprehensive, independent, evidence-driven FORENSIC REVIEW of this entire system.
Not a political review.
Not a carrier review.
Not a plaintiff review.
Not a predetermined conclusion.
A forensic review.
Follow the evidence wherever it goes.
I recently reviewed the analysis published by the Property Insurance Coverage Law Blog concerning Citizens disputes decided through DOAH.
The early dataset examined 38 Citizens DOAH matters in which a decision had been reached.
According to that published analysis:
CITIZENS PREVAILED IN ALL 38.
ZERO FINAL AWARDS TO POLICYHOLDERS IN THAT DATASET.
The analysis also identified cases involving awards of fees and costs to Citizens, including proceedings in which policyholders withdrew.
Those are serious numbers.
But that is only the beginning.
Because Citizens has now published its own numbers.
According to Citizens' own 2025 Claims Committee materials, as of October 14, 2025:
1,662 claim disputes had been referred to DOAH.
1,204 had fully resolved.
Citizens reported that the majority were resolved through what it characterized as voluntary settlement.
Its materials identified a substantial portion involving nominal settlements of $500 or less.
Citizens also reported that policyholders abandoned their disputes in a portion of the cases.
Citizens has publicly defended the process as efficient, impartial, transparent, and successful.
Fine.
Then I have a very simple response:
SHOW FLORIDA THE DATA.
ALL OF IT.
Because there is a gigantic question hiding inside the word "resolved."
WHY?
Why did the Named Insured settle?
Why did the Named Insured withdraw?
Why did the Named Insured abandon the dispute?
Why did someone accept $500?
What was the disputed amount when that $500 was accepted?
Was that truly a favorable resolution?
Was the decision based upon the merits of the claim?
Was it based upon attorney-fee exposure?
Was it based upon a proposal for settlement?
Was it based upon litigation expense?
Was it based upon financial hardship?
Was it based upon procedural exhaustion?
Was it based upon advice from counsel?
Was it based upon fear of continuing?
Did prior DOAH outcomes affect the decision?
Did the policyholder believe he or she could actually prevail?
Did the policyholder believe he or she could financially survive losing?
Would that same policyholder have made the same decision in another forum?
A spreadsheet cannot answer those questions.
A disposition code cannot answer those questions.
Calling something "voluntarily resolved" does not tell Florida WHY it was voluntarily resolved.
That requires interviewing the people who were actually there.
THE NAMED INSUREDS.
And that needs to become a central component of any legitimate forensic examination of this program.
I have personally spoken with insurance professionals, colleagues, and Named Insureds who have described fear, perceived economic exposure, procedural frustration, and a belief that continuing through the process was futile.
Those accounts are important.
But I will make something equally clear:
Those accounts are not yet a systemic forensic finding.
They are investigative leads.
And leads require evidence.
So let's collect it.
I want every reasonably identifiable Named Insured whose Citizens dispute entered this process to have the opportunity to explain, on the record and in his or her own words, what happened.
Those who prevailed.
Those who lost.
Those who settled.
Those who accepted nominal amounts.
Those who withdrew.
Those who abandoned their proceedings.
Those who went all the way to hearing.
Ask them all substantially the same questions.
Obtain their documents where they voluntarily provide them.
Correlate their statements with the actual procedural timeline.
Compare the settlement offers.
Compare the disputed amounts.
Compare the attorney-fee exposure.
Compare the engineering.
Compare the estimates.
Compare the claim determinations.
Compare the ALJ assignments.
Compare the rulings.
Compare the outcomes.
Compare the time to resolution.
Compare everything.
And do it without assuming what the answer is supposed to be.
That is how forensic work is performed.
There is another structural question that must be examined carefully and responsibly.
DOAH administrative law judges are not Citizens employees, and I am NOT accusing any administrative law judge of corruption, bribery, or misconduct without evidence.
But the institutional structure, funding mechanism, contractual relationship, assignment process, case outcomes, and economics of the Citizens/DOAH system are legitimate subjects for independent examination.
So examine them.
If the structure is completely sound, the evidence should demonstrate that.
If it produces unintended incentives or measurable disparities, identify them.
If there is no statistical evidence of bias, say so.
If there is evidence of a problem, say that too.
Nobody gets a predetermined conclusion.
That includes Citizens.
That includes policyholders.
That includes attorneys.
That includes contractors.
That includes experts.
That includes me.
Florida Statute § 627.351 expressly identifies Citizens Property Insurance Corporation as a government entity that is an integral part of the State of Florida.
That same statutory framework requires Citizens to manage those handling claims so Citizens carries out its duty to policyholders to handle claims carefully, timely, diligently, and in good faith.
Florida law also establishes an Office of Inspector General within Citizens with authority involving accountability, integrity, efficiency, compliance, management practices, and investigations concerning matters including fraud, waste, abuse, malfeasance, mismanagement, misconduct, and violations of policy.
So Citizens Property Insurance Corporation:
Use it.
State of Florida Department of Financial Services:
Look at it.
Florida Office of Insurance Regulation:
Measure it.
State of Florida Division of Administrative Hearings:
Help Floridia understand it.
CFO:
Demand the data.
Senate and House of Representatives:
Before this statutory experiment reaches its next major policy decision point, require an accounting of what actually happened.
Not simply how many cases "closed."
WHY THEY CLOSED.
Governor Ron DeSantis:
This system exists today under Florida law. Florida residents deserve measurable evidence showing whether it is accomplishing its intended purpose fairly and effectively.
And to the two major-party nominees asking Floridians to entrust them with the Governor's Office next:
Byron Donalds and Jolly:
Whoever becomes Florida's next Governor will inherit one of the most consequential property-insurance systems in America.
Here is an opportunity for both of you to commit to something that should not be partisan:
DATA.
TRANSPARENCY.
ACCOUNTABILITY.
FAIR CLAIM OUTCOMES.
I would gladly provide my professional time and technical expertise to Citizens, Florida regulators, legislators, the Citizens Inspector General, the incoming administration, or an appropriately constituted independent review effort to help analyze this system.
And understand what I am offering.
I am not offering to prove Citizens wrong.
I am offering to find out whether Citizens is right.
There is a massive difference.
If Citizens is doing something correctly, VALIDATE IT.
If policyholders are submitting unsupported claims, DOCUMENT IT.
If contractors are inflating scopes, EXPOSE IT.
If experts are producing unsupported conclusions, IDENTIFY IT.
If attorneys are manipulating a process, FOLLOW THE EVIDENCE.
And if carrier practices, institutional structures, financial pressures, procedural mechanisms, or claim-handling decisions are producing unjustifiable outcomes:
FIX THEM.
Accountability that only works in one direction is not accountability.
I spend my professional life analyzing property claims from the ground up.
Carrier estimate versus documented scope.
Inspection findings versus coverage conclusions.
Engineering opinion versus physical evidence.
Photographs versus written narrative.
Florida Building Code versus omitted scope.
Repairability versus assumption.
Matching versus availability.
Recorded statements versus subsequent positions.
Requests for information versus information already provided.
Initial determinations versus later reversals.
Claim chronology versus statutory requirements.
Settlement value versus disputed value.
Payment timing.
Repeated inspections.
Repeated examinations.
Repeated requests.
Internal inconsistencies.
And ultimately:
DOES THE FILE SUPPORT THE RESULT?
That question should terrify nobody who believes in the integrity of the process.
In fact, it should be welcomed.
So here is my public offer to Citizens and the State of Florida:
LET'S DO THE REVIEW.
Build the dataset.
Open the legally available records.
Protect legitimately confidential information.
Interview the Named Insureds.
Analyze every disposition category independently.
Analyze the nominal settlements.
Analyze the withdrawals.
Analyze the abandoned cases.
Analyze the final hearings.
Analyze fee and cost awards.
Analyze disputed amounts against ultimate payments.
Analyze claim types.
Analyze engineering vendors.
Analyze adjuster pathways.
Analyze ALJ outcomes without prejudging the ALJs.
Analyze timelines.
Analyze reversals.
Analyze settlements.
Analyze everything.
Then publish the methodology.
Publish the definitions.
Publish the results.
Let Citizens respond.
Let policyholders respond.
Let regulators review it.
Let legislators see it.
Let researchers replicate it.
LET THE DATA SPEAK.
Because this is where I draw the line:
I will not call a settlement proof of wrongdoing.
I will not call an unfavorable ruling proof of corruption.
I will not accuse a judge of misconduct without evidence.
I will not manufacture a conclusion because it fits a narrative.
But I ALSO WILL NOT ACCEPT A GOVERNMENT-CREATED INSTITUTION SAYING "THE SYSTEM WORKS" AS THE END OF THE INVESTIGATION.
Show us.
Prove it with reproducible data.
And if the investigation reveals that policyholders genuinely received an efficient, impartial, economical process:
I WILL SAY SO.
PUBLICLY.
But if the evidence reveals that people were systematically walking away, accepting nominal settlements, or abandoning valid disputes because the economics or structure of the process made continuing practically impossible:
FLORIDA DESERVES TO KNOW THAT TOO.
This is bigger than Citizens.
This is bigger than plaintiffs' attorneys.
This is bigger than insurance carriers.
This is bigger than Republicans.
This is bigger than Democrats.
This is about whether a Florida homeowner can reasonably expect an insurance claim determination to follow the policy, the physical evidence, the applicable law, and the facts.
That should be the standard regardless of who occupies the Governor's Mansion.
Senator Rick Scott
Senator Josh Hawley
United States Senate
U.S. Capitol Office of The Senate Republican Leader
Florida Attorney General's Office
Oval Office, The White House
The underlying issue deserves attention because governmental accountability should withstand examination at every level.
I am a Florida resident.
I am an insurance and construction professional.
I analyze claims for a living.
I am disgusted by some of what I am hearing.
But disgust is not evidence.
SO I WANT THE EVIDENCE.
The claims.
The records.
The interviews.
The settlements.
The withdrawals.
The orders.
The estimates.
The engineering.
The photographs.
The timelines.
The fees.
The payments.
The data.
THE RECEIPTS.
Citizens:
I am looking.
Florida is looking.
And I intend to keep looking.
Not because I want Citizens to fail.
Florida cannot afford for Citizens to fail.
I want Citizens to become an institution so transparent, technically competent, accountable, and evidence-driven that this type of investigation becomes unnecessary.
If Citizens wants help getting there:
My hand is extended.
If Citizens instead wants its conclusions accepted without scrutiny:
That is not going to happen.
If the system works, prove it.
If the system needs improvement, fix it.
If there is something underneath the statistics that Florida has not been told:
The evidence will eventually tell us.
SHOW FLORIDA THE WORK.
Honesty. Integrity. Fact. Fairness.
Chadley Holland
Premier Claim Inspections on 12 LLC
Forensic Property Damage & Insurance Analyst | Appraiser | Umpire | SME | Litigation Support Consultant
