District Court of Appeal of Florida February 29, 2012, No. 3D11-889 (United Property & Casualty Insurance Co. v. Concepcion)

FERNANDEZ, J.

United Property and Casualty Insurance Company appeals the trial court’s non-final order granting the insured’s motion to compel appraisal of a claim under a homeowner’s insurance policy. Because there was an issue of fact as to whether the insured complied with his post-loss obligations, the trial court’s failure to conduct an evidentiary hearing constituted error.