Anti-Public Adjuster Endorsements: Where All 50 States and D.C. Stand as of June 2026

Scope and "as of" date. This article surveys the legal status of policy provisions and endorsements that bar or restrict an insured from retaining a public adjuster, across all 50 states and the District of Columbia, for first-party property insurance, residential and commercial, admitted and surplus lines. The state of the law is described as of June 12, 2026. The article does not cover public adjuster fee caps, solicitation rules, contract-form requirements, or licensing mechanics except where they bear directly on the endorsement question.

The short version: only two states, Texas and Louisiana, have enacted statutes squarely prohibiting anti-public adjuster policy provisions, Tex. Ins. Code § 4102.007 and La. R.S. 22:1274, and Louisiana's prohibition carves out commercial surplus lines policies. Florida has no statute or rule on point, which is why the leading enforceability fight, FAPIA and NAPIA v. Velocity Risk Underwriters, is being litigated there now. Kentucky has moved in the opposite direction, restricting the public adjusting profession itself by statute in 2026, and that law is under constitutional challenge. Everywhere else, the question is governed by general licensing statutes and unsettled public policy arguments. We located no published appellate decision in any jurisdiction ruling on the enforceability of an anti-public adjuster endorsement as of the date above. The decisions that do exist, both from the Barbato litigation against Interstate Fire & Casualty discussed below, are an unpublished New Jersey Appellate Division opinion and a December 2025 federal trial-court dismissal of a public adjuster's tort and antitrust challenge; neither rules on the endorsement's validity as a defense to coverage.

What the endorsement says and where it appears

The form at the center of the dispute is blunt. The Velocity Risk Underwriters endorsement, used in surplus lines policies issued through carriers including Lloyd's syndicates and Interstate Fire & Casualty, makes it a policy condition that the named insured "shall not hire, engage, retain, contract with, or otherwise utilize the services of a public adjuster," licensed or not, to inspect, evaluate, or adjust a covered loss, per the complaint in the Florida litigation discussed below.

These provisions concentrate in non-admitted paper for a structural reason: surplus lines carriers are generally exempt from form filing and approval, so admitted-market form review does not reach the endorsement. NAPIA has said it became aware of the trend in 2021, and its subsequent letters to state attorneys general, reported in early 2023, argued the clauses violate licensing statutes and public policy in the licensing jurisdictions. The endorsements remained largely an E&S phenomenon until late 2024, when the first admitted-market variant appeared in Florida (discussed below), reframing the question from "can a surplus lines carrier impose this" to "can any carrier price it as a voluntary credit."

Texas: the only complete statutory prohibition

Texas is the only state whose prohibition reaches both admitted and surplus lines paper, both residential and commercial. HB 1706 (88th Leg., R.S. 2023) added Tex. Ins. Code § 4102.007, "Right to Contract with License Holder." Subsection (b) provides that a commercial or residential property policy, including any endorsement, may not include a provision prohibiting the insured from contracting with a public insurance adjuster. Subsection (a) lists the carriers covered, and item (7) is the one that matters for this topic: an eligible surplus lines insurer is covered if Texas is the insured's home state as defined by Tex. Ins. Code § 981.002. Subsection (c) adds that the insured is not required to hire one.

The dates matter for claim handling. The Act took effect September 1, 2023, but by its terms § 4102.007 applies only to policies delivered, issued for delivery, or renewed on or after January 1, 2024. A surplus lines policy issued to a Texas home-state insured in, say, October 2023 and never renewed could still carry an arguably operative endorsement; anything in the current policy cycle cannot. TDI summarized the change in Commissioner's Bulletin B-0012-23. The bill analysis is explicit that the legislature was responding to surplus lines carriers stripping the right out of their forms, so there is no serious argument that E&S placements fall outside legislative intent when Texas is the home state. The provision has also survived one attempt to narrow it: HB 3001 (89th Leg., R.S. 2025) would have struck the surplus lines item from subsection (a); it was referred to the House Insurance Committee in March 2025 and died without further action, so § 4102.007 stands unamended as of the date above.

Texas also supplies the strongest recent appellate statement on the legitimacy of regulating this space. In Texas Department of Insurance v. Stonewater Roofing, Ltd. Co., 696 S.W.3d 646 (Tex. 2024), the Texas Supreme Court held that Chapter 4102's licensing requirement (§ 4102.051(a)) and its contractor dual-capacity prohibition (§ 4102.163(a)) regulate nonexpressive professional conduct, not protected speech, and rejected First Amendment and vagueness challenges. Watch the posture: the case reached the court on review of a Rule 91a dismissal, Texas's analogue to a 12(b)(6) motion, so the court decided only that the pleadings stated no cognizable constitutional claim; it reversed Stonewater Roofing, Ltd. Co. v. Texas Department of Insurance, 641 S.W.3d 794 (Tex. App.-Amarillo 2022), which had applied heightened scrutiny. Rehearing was denied September 27, 2024. The opinion's footnote 17 is independently useful to practitioners: it compiles, state by state, the public adjuster licensing statutes of 45 other states, and that court-verified compilation supplies the licensing citations in the survey table below.

Louisiana: directive, reversal, then a statute with a hole in it

Louisiana ran the full regulatory arc in about eighteen months, and the sequence is a caution against citing stale authority. On January 24, 2022, Commissioner Donelon issued Directive 219, ordering all authorized and surplus lines insurers to conform their forms to La. R.S. 22:1704(E)(2), which the Directive read as granting insureds the right to hire a public adjuster. Velocity appealed, and on August 23, 2022, the Division of Administrative Law held Directive 219 legally invalid in In re Velocity Risk Underwriters, LLC, No. 2022-1574-INS. The order rested on two grounds: a directive issued without rulemaking formalities cannot create mandatory prohibitions beyond statutory authority, and § 1704(E)(2), which governs the contract between the adjuster and the insured, contains no language prohibiting anti-public adjuster policy provisions. LDI formally rescinded the Directive on March 29, 2023, by Directive 219-R, which cites the order by docket number and date. Directive 219 should no longer be cited as operative authority, even though public adjuster trade materials still circulate it.

The legislature answered with Act 328 of the 2023 Regular Session (SB 156, Duplessis), enacting La. R.S. 22:1274 effective August 1, 2023. Subsection A prohibits any property insurance policy provision that bars an insured from hiring a public adjuster. Subsection B, added by House amendment, exempts commercial insurance policies written by surplus lines insurers as defined in R.S. 22:46. That exemption is the practical hole: the commercial E&S market is precisely where the endorsements originated. In Louisiana today, the endorsement is prohibited in admitted policies and in residential surplus lines placements, and remains contractually available in commercial surplus lines paper, subject to whatever common-law public policy arguments an insured can mount.

Florida: no statute, live litigation, and an admitted-market pivot

Florida has no statute or Office of Insurance Regulation rule addressing the endorsement, and the 2026 Regular Session, which adjourned sine die on March 13, 2026, produced no legislation on point that we located. What Florida has instead is the country's most consequential test case and a parallel development in the admitted market.

The litigation is Florida Association of Public Insurance Adjusters, Inc. and National Association of Public Insurance Adjusters, Inc. v. Velocity Risk Underwriters, LLC, No. 2025-019878-CA-01, filed October 2025 in the Eleventh Judicial Circuit, Miami-Dade County, Complex Business Division. The associations plead that the endorsement is void as against public policy and unenforceable as a post-loss condition absent a showing of prejudice; that it violates FDUTPA; and, most aggressively, that Velocity's use of an identical endorsement across its surplus lines carrier partners amounts to a concerted refusal to deal under the Florida Antitrust Act, § 542.18, Fla. Stat. The statutory hooks are real even without an express prohibition: Fla. Stat. § 626.8796(6)(c) requires the pre-contract disclosure to state that the insured "is not required to hire a public adjuster but has a right to do so," and Fla. Admin. Code R. 69B-220.201(3)(h) provides that an adjuster "shall not advise a claimant to refrain from seeking legal advice, nor advise against the retention of counsel or the employment of a public adjuster"; the rule binds all licensed adjusters, including those working for insurers. The complaint's foundation case is Larson v. Lesser, 106 So. 2d 188 (Fla. 1958), in which the Florida Supreme Court, 4-3, affirmed a declaratory decree striking the statutory ban on public adjuster solicitation and recognized public adjusting as a lawful occupation that regulation may not practically prohibit. The complaint pairs Larson with Atwater v. Kortum, 95 So. 3d 85 (Fla. 2012), in which the court affirmed the First District's holding that the 48-hour statutory ban on public adjuster solicitation, § 626.854(6), unconstitutionally restricted commercial speech. Atwater modernizes the Larson principle, and it sits in visible tension with Stonewater: Florida's high court treats public adjuster solicitation as protected speech, while Texas's treats public adjusting itself as nonexpressive conduct. Neither decides whether a private policyholder may contract the right away. Note for the file: Larson and Atwater invalidated state statutes under constitutional limits on the police power; whether their reasoning controls a private contractual waiver is exactly the open question, and the 2022 Louisiana administrative order shows how a tribunal can read a licensing scheme as permitting waiver. As of June 12, 2026, no ruling on the merits in the Velocity case has been publicly reported, and an insured-side or carrier-side practitioner should pull the Miami-Dade docket before relying on any characterization of its status.

The admitted-market development may matter more in the long run. Industry commentary reports that OIR approved a voluntary endorsement for at least one admitted Florida personal lines carrier, American Integrity, in November 2024 (filing FCP 24-052992), under which the insured accepts a restriction on public adjuster representation in exchange for a premium credit, and that similar filings from other admitted carriers were anticipated. That figure comes from commentary rather than a published OIR order, so verify it in OIR's I-File filing search before quoting it in a brief or a filing memo. The legal posture of a filed, approved, voluntary, discount-priced endorsement is materially different from an unfiled mandatory E&S condition, and nothing in the Velocity complaint resolves it.

Kentucky: the opposite direction, and a pending constitutional challenge

Kentucky is the only state to have moved against the profession itself rather than against the endorsements. After adopting NAIC-style professional standards in 2023 (HB 232, effective June 29, 2023, amending KRS 304.9-430 and related sections), the 2026 General Assembly passed HB 568, signed April 13, 2026. According to the bill summary and the challengers' pleadings, HB 568 amends KRS 304.9-020 to redefine "negotiate" and "public adjuster" so that public adjusters may no longer negotiate claims with insurers, amends KRS 304.9-430 to bar issuance of new public adjuster licenses (the plaintiffs read the bar as a two-year moratorium), and cuts the maximum fee to 10 percent of settlement proceeds. Public adjusters, contractors, and trade associations filed suit in Jefferson Circuit Court, No. 26-CI-003349, seeking a temporary restraining order and asserting the statute (together with companion bill HB 355) unconstitutionally singles out one side's adjusters while insurer adjusters continue to negotiate freely. A hearing was set for mid-May 2026; we located no publicly reported ruling as of June 12, 2026. Anyone with Kentucky exposure should treat both the statute's operative provisions and the litigation status as unsettled and check the docket directly.

Kentucky matters to the endorsement question for a simple reason: if a state can lawfully phase out public adjusting by statute, the public policy argument against private anti-public adjuster clauses weakens in that state to the vanishing point, and if the courts strike HB 568, the resulting opinion will be the first modern appellate-track authority on how far either legislatures or insurers may go.

The other 45 jurisdictions: licensing without an answer

In every remaining jurisdiction, no statute, regulation, or published bulletin squarely addressing anti-public adjuster policy provisions was located as of June 12, 2026. The operative law is indirect and runs through the licensing scheme. Forty-six states license public adjusters; Alabama, Alaska, Arkansas, and South Dakota do not, per NAPIA's general counsel as reported in trade press in 2023 and repeated in 2026, with Alabama and Arkansas treating insured-side claim representation as effectively reserved to attorneys. The District of Columbia licenses public adjusters through DISB, with a $20,000 bond requirement. Wisconsin is a genuine ambiguity: the Texas Supreme Court's compilation cites Wis. Stat. ch. 629 as comparable adjuster regulation, while several industry licensing guides treat Wisconsin as lacking a dedicated public adjuster license; resolve it against the current Wisconsin statutes before relying on either characterization.

The unsettled question in the licensing states is the one the Louisiana administrative order isolated: does a statute that licenses and regulates public adjusters, and in some states recites that the insured has a right to hire one, render a contractual waiver of that right void, or is the right waivable like most contract rights? South Carolina just joined the recitation camp without answering the waiver question: Act 209 of 2026 (S. 196, signed May 19, 2026, effective on approval) repealed the state's former adjuster chapters (Title 38, chs. 47 and 48) and recodified public adjuster licensing in a new Chapter 92, whose mandatory pre-contract disclosure must state that the insured is not required to hire a public adjuster but has the right to do so, S.C. Code § 38-92-130(F)(2). The same act caps public adjuster fees at ten percent of settlement proceeds and bars any fee before settlement, § 38-92-120(E), the same figure Kentucky's HB 568 imposed. A right-to-hire disclosure statute is the strongest indirect authority an insured-side lawyer has in these states, and the weakest: it recognizes the right without declaring it non-waivable, which is precisely the gap the 2022 Louisiana administrative order drove through.

No appellate court has answered the waiver question anywhere in a published opinion, on our search of published opinions through CourtListener as of the date above. The nearest judicial treatments are the two Barbato decisions discussed in the case law section below: a December 2025 federal trial-court dismissal of a public adjuster's tort and antitrust challenge to the endorsement, and an unpublished New Jersey appellate opinion analyzing a public policy declaratory claim under ripeness doctrine.

The arguments each way are visible in the existing record. For unenforceability, insured-side counsel can point to Larson-style and Atwater-style recognition of public adjusting as a protected lawful occupation, to disclosure statutes like Fla. Stat. § 626.8796(6)(c) and S.C. Code § 38-92-130(F)(2) that frame hiring as a "right," to anti-discouragement rules binding licensed adjusters, to the post-loss condition and prejudice doctrine, and to unfair trade practice and antitrust theories where an MGA standardizes the clause across carriers. For enforceability, carrier-side counsel can point to freedom of contract, to the absence of express prohibitory language in most licensing acts, to the waivability of statutory rights not declared non-waivable, to the premium-reduction consideration in voluntary versions, to the Barbato court's treatment of enforcement as the exercise of a contractual right, and to the structural point that the Texas and Louisiana legislatures thought they needed to pass statutes, which implies the prior law did not already bar the clause. Both sides will find live ammunition here, and an honest survey reports both.

Model laws will not fill the gap soon. The NCOIL Public Adjuster Professional Standards Reform Model Act, adopted by NCOIL's Property and Casualty Insurance Committee on February 2, 2024 and ratified by its Executive Committee on April 14, 2024, regulates the adjusters (pre-approved contract forms, fee caps of 15 percent non-catastrophic and 10 percent catastrophic, conflict rules, fiduciary handling of funds); it says nothing about insurer policy language, so enacting it does not prohibit the endorsement. The NAIC's Public Adjuster Licensing Model Act (#228, 2005) is the template for most state licensing acts and likewise contains no anti-endorsement provision; amendments were under discussion at the NAIC as of 2024, and their current status should be checked against NAIC materials before being characterized.

Survey table: all 50 states and D.C.

Licensing citations for the states marked with an asterisk are drawn from footnote 17 of Stonewater Roofing, 696 S.W.3d 646 (Tex. 2024), the Texas Supreme Court's own compilation, and reflect the law as of mid-2024; confirm currency before briefing. South Carolina shows why: the footnote's cite to former §§ 38-48-10 and 38-48-20 was superseded when Act 209 of 2026 repealed chapters 47 and 48 effective May 19, 2026, and the table below reflects the recodification. "None identified" in the third column means no statute, regulation, or published bulletin squarely addressing anti-public adjuster policy provisions was located as of June 12, 2026; it is a statement of search results, not a guarantee of absence.

Case law

Four decided cases carry the principal weight, the Barbato decisions supply the first judicial treatments of the endorsement itself, and the pending dockets supply the rest.

Texas Department of Insurance v. Stonewater Roofing, Ltd. Co., 696 S.W.3d 646 (Tex. 2024) (opinion). Holding: Chapter 4102's public adjuster licensing requirement and contractor dual-capacity prohibition regulate professional conduct, not protected speech, and the pleadings stated no First or Fourteenth Amendment claim. Posture: review of a Rule 91a dismissal, decided on the pleadings; the court expressly did not apply any tier of scrutiny to the statutes' merits. Controlling in Texas; persuasive elsewhere on the constitutional footing of PA regulation. Rehearing denied September 27, 2024.

Stonewater Roofing, Ltd. Co. v. Texas Department of Insurance, 641 S.W.3d 794 (Tex. App.-Amarillo 2022) (opinion), rev'd, 696 S.W.3d 646 (Tex. 2024). Cited here only because it still circulates: the intermediate court's holding that public adjusting "necessarily and inextricably" involves protected speech did not survive review and should not be relied on.

Larson v. Lesser, 106 So. 2d 188 (Fla. 1958) (opinion). Holding: a statutory ban on public adjuster solicitation was unconstitutional because it would practically prohibit a lawful, legislatively recognized occupation without a public-welfare justification. Posture: affirmance of a declaratory decree, over a three-justice dissent. Controlling Florida authority on the legitimacy of the profession; it does not decide whether an insured may contractually waive the right to hire one, which is the question now before the Miami-Dade court.

Atwater v. Kortum, 95 So. 3d 85 (Fla. 2012) (opinion). Holding: the 48-hour statutory ban on public adjuster solicitation after a loss event, § 626.854(6), Fla. Stat., unconstitutionally restricted commercial speech and was not narrowly tailored to the state's interests in ethical conduct and homeowner protection. Posture: affirmance of the First District's invalidation of the statute. Controlling Florida authority that public adjuster solicitation is protected commercial speech; like Larson, it shields the profession from state restriction without deciding whether an insured may contractually waive the right to hire one.

Barbato v. Interstate Fire & Casualty Co., No. 25-cv-5312, 2025 U.S. Dist. LEXIS 259094 (S.D.N.Y. Dec. 15, 2025) (docket materials). The first federal decision addressing the endorsement in operation. A New Jersey public adjusting firm sued after the insurer enforced an anti-public adjuster endorsement and the insured terminated the firm's contract. The court granted the insurer's motion to dismiss: the complaint did not plausibly allege that the endorsement violated any law, the insurer's enforcement was the exercise of a contractual right and therefore not wrongful conduct supporting tortious interference, and the restraint-of-trade count failed for want of a pleaded product or geographic market. Posture caveats: a trial-level ruling on the pleadings under New York law, on tort and antitrust theories; it is not a holding that the endorsement is valid as a defense to coverage, and published summaries conflict on whether the dismissal was with or without prejudice, so pull the opinion from the S.D.N.Y. docket before characterizing it. Carrier-side counsel will cite it; insured-side counsel will distinguish it.

Barbato v. Interstate Fire & Casualty Co., No. A-0881-24 (N.J. Super. Ct. App. Div. Nov. 3, 2025) (unpublished) (opinion). The companion state appeal. The operative complaint sought only a declaration that the endorsement violates New Jersey public policy, and the panel's analysis proceeds under declaratory judgment justiciability and ripeness doctrine. The opinion is unpublished and non-precedential under New Jersey Rule 1:36-3, which sharply limits citation of unpublished opinions in New Jersey courts; read the opinion itself before relying on any characterization of its disposition.

Pending, not authority: FAPIA & NAPIA v. Velocity Risk Underwriters, LLC, No. 2025-019878-CA-01 (Fla. 11th Jud. Cir., Miami-Dade, Complex Business Div., filed Oct. 2025), and the Kentucky HB 568 challenge, No. 26-CI-003349 (Jefferson Cir. Ct., filed 2026). Neither has produced a reported merits ruling as of June 12, 2026. The 2022 Louisiana administrative order invalidating Directive 219 is likewise not judicial precedent, though it remains the only adjudicated reading of a licensing statute on the waiver question; the Barbato decisions approached the endorsement through tort, antitrust, and justiciability doctrine rather than through a licensing scheme, and carrier counsel will cite both.

Practical takeaways

For coverage counsel. Venue and paper type decide the starting point. A Texas home-state risk on a policy issued or renewed on or after January 1, 2024 makes the endorsement void by statute regardless of admitted or E&S status; a Louisiana commercial surplus lines risk leaves it contractually intact and pushes the fight to common-law public policy; Florida and the other 44 jurisdictions are open ground where the Velocity theories (post-loss condition prejudice, FDUTPA analogues, concerted refusal to deal) and the carrier-side waiver-and-consideration defense are both untested on appeal. Expect carrier-side counsel to cite the S.D.N.Y. Barbato dismissal; insured-side counsel should be prepared to distinguish it as a tort and antitrust ruling, on the pleadings, that did not adjudicate the endorsement's validity as a defense to coverage. Do not cite Directive 219, the Amarillo Stonewater opinion, or any characterization of Larson or Atwater as resolving contractual waiver.

For underwriting and product. The Texas statute voids the endorsement for Texas home-state insureds on any policy delivered, issued for delivery, or renewed on or after January 1, 2024, admitted or E&S, and Louisiana bars it outside commercial E&S. Elsewhere, the mandatory E&S version carries litigation and regulatory-attention risk that is now quantifiable (an antitrust count aimed at an MGA's standardized form across multiple carriers, answered so far by one favorable federal dismissal on the pleadings), while the Florida-style voluntary discount endorsement, filed and approved, is the version most likely to survive scrutiny and most likely to spread. Any carrier considering a me-too filing should price the possibility that the Velocity court voids the mandatory version on public policy grounds broad enough to cast doubt on the voluntary one.

For claims and reserving. When a public adjuster appears on a claim governed by a policy carrying the endorsement, the safe handling posture outside Texas and Louisiana is to adjust the loss on the merits while preserving the condition issue, because a denial premised solely on the insured's retention of a PA invites a bad faith file in any state whose law requires prejudice for post-loss condition breaches, and invites a referral where an anti-discouragement rule like Florida's R. 69B-220.201 applies to licensed adjusters. In Kentucky, confirm the current operative status of HB 568 before treating a PA's negotiation activity as unauthorized; the statute is under challenge and the docket, not this article, is the source of truth on any injunction.

What remains unsettled

Three questions are genuinely open as of June 12, 2026, and each is worth a calendar entry. First, whether any court will hold a mandatory anti-public adjuster endorsement void as against public policy; Velocity in Miami-Dade is the lead vehicle, and the S.D.N.Y. Barbato dismissal shows the early carrier-side trajectory when the clause is attacked in tort rather than tested as a coverage defense. Second, whether a filed, voluntary, premium-credited waiver endorsement in the admitted market stands on different footing; no regulator has disapproved one and no court has examined one. Third, whether Kentucky's HB 568 survives constitutional review; if it does, the public policy argument against private clauses collapses in Kentucky, and if it falls, the opinion will be the first modern precedent mapping the outer limits of restricting insured-side representation. Watch the Barbato dockets as well; an appeal or a refiling there could produce the first appellate treatment of the endorsement. A practitioner relying on this survey after any of those dockets moves should re-verify before citing it.

Sources

Primary sources: statutes, bills, and regulator materials

1. Tex. Ins. Code ch. 4102 (including § 4102.007): https://statutes.capitol.texas.gov/GetStatute.aspx?Code=IN&Value=4102
2. HB 1706 (Tex. 2023) Senate Research Center bill analysis: https://capitol.texas.gov/tlodocs/88R/analysis/html/HB01706S.htm
3. La. Act 328 of 2023 (SB 156), enrolled, enacting La. R.S. 22:1274: https://legis.la.gov/legis/ViewDocument.aspx?d=1332546
4. LDI Directive 219-R (Mar. 29, 2023), formally rescinding Directive 219 and citing the invalidation order by docket number: https://www.ldi.la.gov/docs/default-source/documents/legaldocs/directives/r/directive219-r-final
5. In re Velocity Risk Underwriters, LLC, No. 2022-1574-INS (La. Div. Admin. Law Aug. 23, 2022), order holding Directive 219 invalid: https://www.propertyinsurancecoveragelaw.com/wp-content/uploads/2023/03/Division-of-Administrative-Law-Order-on-Directive-219-1.pdf
6. Fla. Stat. § 626.8796 (2025): https://www.flsenate.gov/Laws/Statutes/2025/626.8796
7. Ky. HB 568 (2026), bill summary and history: https://legiscan.com/KY/bill/HB568/2026
8. S.C. Act 209 of 2026 (S. 196), enrolled text, status, and effective date: https://www.scstatehouse.gov/sess126_2025-2026/bills/196.htm
9. NCOIL Public Adjuster Professional Standards Reform Model Act, as adopted (committee adoption Feb. 2, 2024; ratified Apr. 14, 2024): https://ncoil.org/wp-content/uploads/2024/02/NCOIL-Pub.-Adj.-Model-P%5E0C-Cmte-Adopt-2-2-24-1.pdf

Case opinions

1. Tex. Dep't of Ins. v. Stonewater Roofing, Ltd. Co., 696 S.W.3d 646 (Tex. 2024): https://www.txcourts.gov/media/1458705/220427.pdf
2. Stonewater Roofing, Ltd. Co. v. Tex. Dep't of Ins., 641 S.W.3d 794 (Tex. App.-Amarillo 2022), rev'd: https://caselaw.findlaw.com/court/tx-court-of-appeals/2160986.html
3. Larson v. Lesser, 106 So. 2d 188 (Fla. 1958): https://www.courtlistener.com/opinion/1735807/larson-v-lesser/
4. Atwater v. Kortum, 95 So. 3d 85 (Fla. 2012): https://caselaw.findlaw.com/fl-supreme-court/1605404.html
5. Barbato v. Interstate Fire & Cas. Co., No. A-0881-24 (N.J. Super. Ct. App. Div. Nov. 3, 2025) (unpublished): https://www.njcourts.gov/system/files/court-opinions/2025/a0881-24.pdf
6. Barbato v. Interstate Fire & Cas. Co., No. 25-cv-5312 (S.D.N.Y.), docket materials including the Oct. 17, 2025 remand opinion; the Dec. 15, 2025 dismissal is reported at 2025 U.S. Dist. LEXIS 259094: https://law.justia.com/cases/federal/district-courts/new-york/nysdce/1:2025cv05312/644852/19/

Pending litigation filings

1. Complaint, FAPIA & NAPIA v. Velocity Risk Underwriters, LLC, No. 2025-019878-CA-01 (Fla. 11th Cir. Ct. 2025): https://www.insurancejournal.com/app/uploads/2025/10/FAPIA-complaint.pdf

News and commentary

1. Insurance Journal magazine feature on the Velocity suit and carrier tactics (Nov. 3, 2025): https://www.insurancejournal.com/magazines/mag-features/2025/11/03/845625.htm
2. LEX 18, "Kentucky HB 568 restricting public adjusters draws legal challenge" (May 2026): https://www.lex18.com/news/covering-kentucky/kentucky-hb-568-restricting-public-adjusters-draws-legal-challenge-ahead-of-monday-hearing
3. Insurance Law Hawaii, summary of the S.D.N.Y. Barbato dismissal (Mar. 9, 2026): https://www.insurancelawhawaii.com/2026/03/policy-provision-prohibiting-the-hiring-of-public-adjuster-upheld.html
4. Industry commentary on Florida admitted-market voluntary endorsement filings (Jan. 2026): https://johnsonstrategiesllc.com/are-you-anti-public-adjuster