Extract to table

The policyholder bears the initial burden of demonstrating that a loss falls within the coverage grant; that is, VHG must show that the Grand Key Resort suffered "direct physical loss or damage" from a covered peril

If there is any ambiguity in whether the term "flood" encompasses hurricane-generated storm surge, that ambiguity must be resolved in VHG's favor

While Florida appellate decisions directly addressing whether storm surge is "flood" are limited, the broader pattern of Florida insurance jurisprudence strongly favors narrow construction of flood exclusions and strict adherence to the rule that the insurer must clearly and unambiguously exclude a peril to avoid coverage

The Florida Supreme Court has repeatedly emphasized that an insurer seeking to rely on an exclusion must demonstrate that the exclusion "clearly and unambiguously" applies to the loss at issue

Where the exclusion is susceptible to more than one reasonable interpretation, it must be construed against the insurer