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Policy Limits Demands and the New Safe Harbors, Part 1: Florida Bad Faith Fundamentals, HB 837, and the Developing Landscape

HB 837 rewrote the ground rules of Florida bad faith litigation. This program equips attorneys to evaluate common-law and statutory bad faith claims, apply the duties and standards that govern insurer conduct, and account for the 90-day safe harbor and the questions it left unresolved.

2026-10-21 12:00:00

Program Details

2026-10-21 12:00:00

2026-10-21 12:00:00

2h CLE Credits

2026-10-21 12:00:00

Program Details

2026-10-21 12:00:00

Program Details

2026-10-21 12:00:00

Over 1,000+ webinars

2026-10-21 12:00:00

Course Overview

HB 837 didn’t amend Florida bad faith law at the margins. It reset the framework, and courts are still sorting out the rest

2026-10-21 12:00:00

Florida bad faith law developed over decades through common-law doctrine and the statutory remedy of Fla. Stat. § 624.155. HB 837, enacted in March 2023, reshaped that framework in one stroke. It introduced a 90-day safe harbor, added claimant-side good faith duties, and unsettled rules practitioners had relied on for years.

The threshold questions now decide cases. Whether a claim is first-party or third-party determines which duties the insurer owes. Whether the insurer resolved the claim within the 90-day safe harbor can end a bad faith action before it begins. And the fate of the underlying claim controls whether a bad faith case ever ripens. Miss one of these questions and the strongest facts never reach a jury.

This program supplies the grounding to practice under the new framework. Attendees will evaluate common-law and statutory claims, apply the governing duties and standards, and account for the safe harbor. They will leave with a working map of what HB 837 changed, what survives, and which questions remain open. That judgment is work no search result supplies.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
Foundations of Florida Bad Faith
How Florida’s bad faith framework developed, and why that history still controls how claims are pled and proved today.
02
Common-Law and Statutory Claims
How common-law and statutory bad faith theories differ across first-party and third-party claims, and what each requires.
03
Insurer Duties and Standards
The duties insurers owe under Florida law and the standards used to evaluate whether conduct crosses into bad faith.
04
The Underlying Claim
How the underlying claim shapes a later bad faith action, and what that relationship means for strategy and timing.
05
HB 837’s Key Changes
What HB 837 changed, including the 90-day safe harbor, and how those changes alter practice under Fla. Stat. § 624.155.
06
Developing and Unresolved Law
How HB 837’s changes fit within established Florida bad faith law, and the unresolved questions courts are only beginning to answer.

Program schedule

clock 12:00 pm - 1:00 pm EST

Florida Bad Faith Fundamentals: Foundations, Duties, and the Underlying Claim

This session introduces the fundamental principles of Florida bad faith law, tracing the foundations and development of the doctrine through both common law and statutory claims, including first-party and third-party actions. It examines the duties insurers owe, the standards used to evaluate whether an insurer acted in bad faith, and the relationship between the underlying claim and a bad faith action.

Brenna SpinnerBrenna Spinner
clock 1:10 pm - 2:10 pm EST

HB 837 and After: The 90-Day Safe Harbor, Its Impact, and the Questions Still Open

This session turns to the significant changes enacted through HB 837, including the 90-day safe harbor, and their impact on established Florida bad faith law. It addresses how those changes fit within existing Florida law and closes with the developing law and the questions that remain unresolved after HB 837.

Brenna SpinnerBrenna Spinner
Brenna Spinner

Brenna Spinner

Swope, Rodante, Newsome & Steinberg

Brenna Spinner

Brenna Spinner

Swope, Rodante, Newsome & Steinberg

Brenna Spinner is a litigation and appellate attorney at Swope, Rodante, Newsome & Steinberg, where she represents injured clients and policyholders wronged by insurers in bad faith, personal injury, civil, and appellate matters across state and federal courts. Her practice runs on careful legal writing and strategic case development, and her results range from a victory on a novel issue of law before the Supreme Court of Maryland to successful outcomes for hundreds of clients. In 2026 alone, she holds a Best Lawyers: Ones to Watch in America listing and presents twice for the Florida Justice Association on insurance cases and Florida case law.

Education & Credentials

Ms. Spinner earned her J.D., with honors, from The George Washington University Law School in 2016, following a B.A., summa cum laude, from Salisbury University. At GW she was a member of the George Washington Law Review, chaired a committee of the GW Moot Court Board, competed in moot court, and taught legal research, writing, and advocacy to first-year students as a Dean's Fellow. She is admitted in Florida, Maryland, and the District of Columbia, before the Eleventh Circuit Court of Appeals, and in six federal district courts: the Middle and Southern Districts of Florida, the Northern and Southern Districts of Indiana, the District of Columbia, and the Eastern District of Wisconsin.

Recognition & Leadership

Ms. Spinner's recognition spans the courtroom and the podium. She has been named to Best Lawyers: Ones to Watch in America (2026) and recognized by The National Trial Lawyers (2025). The Florida Justice Association has twice given her a statewide platform in 2026: she presented "Special Considerations in Insurance Cases" at the FJA's Proposal for Settlement Webinar and delivered the "Case Law Update" at the FJA Annual Convention.

Professional Involvement

Ms. Spinner is an EAGLE member of the Florida Justice Association and belongs to the Tampa Bay Trial Lawyers Association, the American Association for Justice, the Hillsborough County Bar Association, the Florida Bar Young Lawyers Division, the American Bar Association, and the Military Spouse J.D. Network. Service has run through her entire career: she volunteered at the District of Columbia's landlord-tenant resource center assisting pro se litigants, and in law school represented indigent clients facing eviction through a student legal clinic.

Experience

At Swope, Rodante, Newsome & Steinberg, Ms. Spinner litigates insurance bad faith, personal injury, civil, and appellate matters for clients whose lives have been changed by injury or injustice. She began her career at a leading Washington, D.C. litigation firm, handling every phase of litigation and securing a successful outcome on a novel issue of law before the Supreme Court of Maryland. In 2019 she devoted her practice to individuals denied Social Security Disability benefits and obtained successful results for hundreds of them. She brings that same client-centered commitment, now paired with big-firm litigation and appellate experience, to every case she handles today.
Brenna Spinner

Brenna Spinner

Swope, Rodante, Newsome & Steinberg

Brenna Spinner is a litigation and appellate attorney at Swope, Rodante, Newsome & Steinberg, where she represents injured clients and policyholders wronged by insurers in bad faith, personal injury, civil, and appellate matters across state and federal courts. Her practice runs on careful legal writing and strategic case development, and her results range from a victory on a novel issue of law before the Supreme Court of Maryland to successful outcomes for hundreds of clients. In 2026 alone, she holds a Best Lawyers: Ones to Watch in America listing and presents twice for the Florida Justice Association on insurance cases and Florida case law.

Education & Credentials

Ms. Spinner earned her J.D., with honors, from The George Washington University Law School in 2016, following a B.A., summa cum laude, from Salisbury University. At GW she was a member of the George Washington Law Review, chaired a committee of the GW Moot Court Board, competed in moot court, and taught legal research, writing, and advocacy to first-year students as a Dean's Fellow. She is admitted in Florida, Maryland, and the District of Columbia, before the Eleventh Circuit Court of Appeals, and in six federal district courts: the Middle and Southern Districts of Florida, the Northern and Southern Districts of Indiana, the District of Columbia, and the Eastern District of Wisconsin.

Recognition & Leadership

Ms. Spinner's recognition spans the courtroom and the podium. She has been named to Best Lawyers: Ones to Watch in America (2026) and recognized by The National Trial Lawyers (2025). The Florida Justice Association has twice given her a statewide platform in 2026: she presented "Special Considerations in Insurance Cases" at the FJA's Proposal for Settlement Webinar and delivered the "Case Law Update" at the FJA Annual Convention.

Professional Involvement

Ms. Spinner is an EAGLE member of the Florida Justice Association and belongs to the Tampa Bay Trial Lawyers Association, the American Association for Justice, the Hillsborough County Bar Association, the Florida Bar Young Lawyers Division, the American Bar Association, and the Military Spouse J.D. Network. Service has run through her entire career: she volunteered at the District of Columbia's landlord-tenant resource center assisting pro se litigants, and in law school represented indigent clients facing eviction through a student legal clinic.

Experience

At Swope, Rodante, Newsome & Steinberg, Ms. Spinner litigates insurance bad faith, personal injury, civil, and appellate matters for clients whose lives have been changed by injury or injustice. She began her career at a leading Washington, D.C. litigation firm, handling every phase of litigation and securing a successful outcome on a novel issue of law before the Supreme Court of Maryland. In 2019 she devoted her practice to individuals denied Social Security Disability benefits and obtained successful results for hundreds of them. She brings that same client-centered commitment, now paired with big-firm litigation and appellate experience, to every case she handles today.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CT2.0
FL2.0
GA2.0
HI2.0
MO2.4
MS2.0
ND2.0
NH120.0
NJ2.0
NM2.0
NY2.0
OH2.0
PA2.0
TN2.0
VT2.0
WA2.0
WI2.0

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Approved
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Connecticut
Approved
Florida
Pending
Georgia
Pending
Hawaii
Approved
Mississippi
Pending
Missouri
Approved
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Dakota
Approved
Ohio
Approved
Pennsylvania
Approved
Tennessee
Approved
Vermont
Approved
Washington
Approved
Wisconsin
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs