The Parrish Rule

In Parrish v. State Farm Florida Insurance Co. (Fla. 2023), the Florida Supreme Court addressed whether a public adjuster compensated by contingency fee can serve as a "disinterested" appraiser. The holding runs against it: an appraiser cannot be disinterested where he or she, or a firm in which he or she has an interest, is to be compensated for public adjusting services on a contingency. The practical result is that a PA serving as appraiser on a file where the PA firm holds a contingency fee should be compensated flat-fee or hourly for the appraisal role, not on the contingency.

This is why Ocean Point bills appraisal work separately. Where the firm holds a contingency fee on the public adjusting side, the appraisal role is billed flat-fee or hourly rather than on contingency, so the appraiser can stand as disinterested under Parrish.