A woman walks through debris at the Seabreeze trailer park along the Overseas Highway in the Florida Keys after Hurricane Irma slammed into the Lower Florida Keys. (Photo: Al Diaz/Miami Herald via AP, File)

A federal district court in Florida has ruled that a Miami homeowner could not recover under a lender-placed insurance policy for damage caused to his home by Hurricane Irma where he was named as the borrower and not the named insured and where he did not allege that the damage exceeded the amount due on his mortgage.

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