Expert Witness Blog
In the case of SFR Services, LLC v. American Coastal Insurance Company, No. 2:22-cv-505 (M.D. Fla. Feb. 7, 2025), the testimony of a Forensic Engineering Expert Witness played a pivotal role in determining the cause and extent of property damage following Hurricane Irma. The case illustrates how expert analysis, even when based on virtual inspection, can meet legal standards of admissibility under federal law.
Background of the Case
SFR Services, LLC filed a lawsuit against American Coastal Insurance Company (ACIC) for failing to pay for damage caused to a property during Hurricane Irma. SFR, acting as the contractor and assignee of the insured, alleged that the insurer breached its obligations under the policy by denying or underpaying for covered losses.
Central to the case was the question of what caused the roof and interior damage—whether it was due to hurricane-force winds (as claimed by SFR), or other factors like age-related deterioration or poor maintenance (as argued by the insurer).
Role of the Forensic Engineering Expert Witness
To support its claims, SFR retained Grant Renne, a licensed professional engineer and experienced forensic investigator, who had completed over 6,000 damage assessments and participated in more than 400 legal cases. Renne’s role as a forensic engineering expert was to determine the cause and scope of the damage, and whether it aligned with what would be expected from hurricane-force winds.
Renne conducted a virtual inspection using photographs, maintenance records, and contractor notes, as the property had already been repaired by the time of his analysis. He reviewed these materials to form an opinion that the damage was consistent with wind uplift and water intrusion resulting from Hurricane Irma.
Court Proceedings and Findings
ACIC challenged the admissibility of Renne’s testimony, filing a Daubert motion to exclude it on the grounds that his opinion was not based on personal observation or physical inspection. The insurer argued that Renne’s methodology was inherently unreliable because it was based solely on photos and reports provided by SFR and its contractors.
The United States District Court for the Middle District of Florida, however, denied the motion and allowed Renne’s testimony. The court applied the Daubert standard, which evaluates expert testimony based on relevance and reliability. The court acknowledged that while in-person inspections are generally preferable, the lack of a physical site visit did not automatically render Renne’s opinion inadmissible.
The judge noted that Renne relied on extensive photographic documentation, contractor invoices, and other materials to reach his conclusions. The court ruled that any alleged shortcomings in his methodology were best addressed through cross-examination at trial rather than exclusion. As such, Renne’s forensic engineering testimony was admitted, and the case was allowed to proceed.
Legal Significance
This case highlights the critical role of expert testimony in property damage litigation, particularly in insurance disputes where causation is a key issue. It also affirms that modern technological alternatives—such as virtual inspections—can satisfy the requirements for expert analysis under Daubert, provided the expert has a sufficient foundation in fact and uses a methodologically sound approach.
The ruling serves as an important precedent for cases where traditional inspection methods are unavailable, emphasizing flexibility in the evaluation of expert methods.
Conclusion
SFR Services, LLC v. American Coastal Insurance Company demonstrates the significant impact a Forensic Engineering Expert Witness can have in insurance disputes, even when relying on virtual evidence. The court’s decision to admit Renne’s testimony reinforces that expert opinions do not need to be based on personal observation if they are founded on sufficient documentation and appropriate methodology. This case reflects the evolving standards of forensic investigations and the legal system’s recognition of reliable alternative approaches to traditional expert analysis.