William and Cynthia Hamilton's mobile home was destroyed by Hurricane Ivan.  At the time of the loss, the Hamiltons possessed flood insurance with the National Flood Insurance Program ("NFIP") (offering coverage for the peril of flood) as well as homeowner's insurance with Citizens Property Insurance Corporation ("Citizens") (offering coverage for, among other perils, windstorm, but excluding damage caused by flooding).  The insureds submitted a claim to NFIP under their flood policy for damage/loss to the mobile home, out buildings, and personal property.  NFIP issued the full flood policy limits for the Hamiltons' claim.  Thereafter, the insureds submitted a claim to Citizens under their homeowner's policy, and Citizens issued payment for wind-related damages in the amount of $6,370.  The insureds then filed suit against Citizens seeking to recover the full policy limits of the homeowner's policy. 

At trial, the jury found that wind had caused a total loss of the Hamiltons' mobile home and awarded Citizens' policy limits for the loss of the home; the jury also assigned damage amounts for the insureds' out buildings based on jury instructions that the homeowner's policy provided for payment of losses on the basis of replacement cost.  Additionally, the court awarded prejudgment interest on the entire damages award from the date of loss. 

On appeal to the First DCA, the appeals court found as follows: 

1. The trial court did not abuse its discretion in ruling that Citizens could not reference the dollar amount paid by NFIP to the insureds under the flood policy;
2. There was no apparent prejudice where the trial court allowed the insureds to admit into evidence the county's determination that the mobile home had been substantially damaged for the purpose of proving that wind caused a constructive total loss of the mobile home before flood surge washed away the remains;
3. The trial court did not abuse its discretion in declining Citizens' proposed jury instruction regarding the insured's burden to prove damages caused solely by wind;
4. The trial court did not abuse its discretion in failing to instruct the jury to apply the "total loss recovery" rule;
5. There was reversible error where the trial court instructed the jury to measure damages to the out buildings by replacement cost value; and
6. There was reversible error where the trial court awarded prejudgment interest on the entire damages award, on the basis that valued law policy did not apply to the out buildings, and therefore the calculation of interest for this portion of the insureds' claim should be calculated in accordance with the homeowner's policy.