An arbitration decision that is emailed as an attachment to the arbitrator’s own invoice does not satisfy Florida’s rule for serving court documents by email, the Second District Court of Appeal held on November 13, 2026, in Koppert v. Homeowners Choice Property & Casualty Insurance Company, Nos. 2D2025-0106, 2D2025-0124, and 2D2025-0125 (consolidated), a ruling on whether an arbitration decision emailed as an invoice attachment can start the twenty-day clock for demanding a trial. Judge Silberman wrote the opinion. Judges Northcutt and Labrit concurred.
The case
Timothy Koppert, as personal representative of the estate of Eldon Koppert, pursued three separate circuit court cases against Homeowners Choice Property & Casualty Insurance Company over hurricane damage to Eldon Koppert’s home: a breach of contract claim over an initial coverage dispute, a negligence claim alleging the insurer failed to properly reattach a plastic tarp on the roof after an inspection, and a second breach of contract claim after the home suffered further damage in a second hurricane. Eldon Koppert died while the appeal was pending, and Timothy Koppert was substituted as appellant; the opinion notes all references to the trial court proceedings are to Eldon Koppert. All three cases went to nonbinding arbitration, and the arbitrator found in favor of Homeowners Choice.
How the arbitration decision was emailed
On September 16, 2024, the arbitrator emailed the decision to the parties as an attachment, with a subject line reading “New Invoice from Nicholas Mediation – Invoice 2024.0565P Case: Koppert v. Homeowners Choice.” The email was sent from a QuickBooks notification address, and what first appeared in the message was invoice detail, the mediation firm’s logo, the invoice amount, and a “Review and pay” button, with the email stating it was “Powered by QuickBooks.” The first sentence of the email said, “Attached please find your pro-rata share of Mediation and/or Arbitration, including all related services, as well as the Arbitration Order and a copy of our firm’s W9.” Koppert’s counsel testified he thought the email “was simply an invoice for services as it was only a few days after the arbitration,” so he forwarded it internally “to instruct the board bookkeeping to timely pay the invoice.”
The twenty-day clock
Under Florida Rule of Civil Procedure 1.820(h), a party who wants to reject a nonbinding arbitration decision must file a request for trial within twenty days of service of the decision. Homeowners Choice moved for judgment in conformance with the arbitration decision on October 14, attaching a copy of the decision to its motion. Koppert filed his demand for trial de novo that same day. The trial court ruled the demand untimely, reasoning it was due by October 7, and entered final judgment for Homeowners Choice in all three cases.
Why an arbitration decision emailed as an invoice attachment is not service. Rule 1.820(h) requires that the arbitration decision be served, and service must comply with Florida Rule of General Practice and Judicial Administration 2.516. That rule requires that “the title of the e-mail message serving a document must begin with” the words “SERVICE OF COURT DOCUMENT,” followed by the case number and an abbreviation of the case style. The arbitrator’s email did not do this; its subject line was about an invoice. The Second DCA rejected the insurer’s argument that section 44.103(5), Florida Statutes, required only that the decision “be presented to the parties in writing,” holding that the statute has to be read together with rule 1.080(a) and rule 2.516(b)(2)(C), which govern how that presentation must actually be served.
Timely after all
Because Koppert was never properly served with the arbitration decision, the court held he first learned of it when Homeowners Choice attached it to its October 14 motion, and he filed his trial demand that same day. The demand was therefore timely, the final judgment for Homeowners Choice was reversed, and the cases were remanded for further proceedings.
What this does and does not mean
Because the court resolved the case on service, it did not reach Koppert’s separate arguments that any delay was due to excusable neglect or was excused by hurricane-related administrative orders. The ruling addresses only whether this particular email satisfied the service rule for arbitration decisions; it does not address other methods of serving such a decision. The opinion is “subject to revision prior to official publication.”
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Read the opinion (PDF): Download the opinion (PDF)
Source: Koppert v. Homeowners Choice Property & Casualty Insurance Company, Nos. 2D2025-0106, 2D2025-0124, 2D2025-0125 (Fla. 2d DCA Nov. 13, 2026). This article is general information, not legal advice.