Quintero was transferred to a supervisor but got their voicemail and didn't pay for renewal.

Three weeks later, in the early hours of May 25, a neighbor's surveillance camera captured a dark pickup truck towing Quintero's boat and its trailer from his driveway. Hours later, Quintero called Geico to renew his boat insurance policy. Quintero seemed unaware his policy had expired and said, "Something happens out there, you know, you want to be insured," according to transcript excerpts in the ruling.

Geico reinstated Quintero's policy and backdated it from May 5 — after he confirmed the boat wasn't damaged and said he had kept it at his house and had seen it every day.

That afternoon, after reporting his boat stolen, Quintero called Geico to make a claim. He said he'd last seen it the night before, according to the ruling, and said when his wife asked where it was he'd assumed it was still there and went to work.

Quintero sued after Geico declined coverage, but U.S. District Judge Ursula Ungaro in the Southern District of Florida sided with the insurer.

That was the right call, according to the Eleventh Circuit, which found the plaintiff's statements about the boat were key to Geico's decision to insure it.

"Viewed from the perspective of a reasonable insurer, Quintero's misrepresentation that the boat was in his home and possession was material, as no 'prudent and intelligent insurer' would accept the risk of insuring stolen property that is no longer in the insured's possession," the opinion said. "When Quintero made the call at 7:28 a.m. on May 25, the boat had already been missing for two and a half hours, and Quintero had a duty to disclose that fact even if Geico did not directly ask him."

'Uberrimae fidei' doctrine

The panel also found the boat wasn't actually covered when it was stolen because the policy had expired. And though Quintero argued that didn't matter because he renewed it, the appeals court looked to the federal maritime doctrine of "uberrimae fidei," which says boat owners have a duty to "fully and voluntarily disclose" all material facts to insurers.

The opinion said that duty remains even if the policyholder made a mistake, forgot or was never asked. Otherwise, the policy is void from the beginning.

And though Quintero correctly argued that the doctrine only applies at the start of a new policy, the appellate panel found Geico had issued a new policy because the original one expired.

Jack Reiter, of GrayRobinson in Miami and appellate counsel for Geico, said its notable that the ruling leaned on the federal maritime doctrine.

"This opinion is significant because it reinforced the applicability of the historical doctrine of uberrimae fidei, which embodies the highest degree of good faith and places the burden on the insured to make full and voluntary disclosure of facts to an insurer that would be material to the decision to issue a marine insurance policy," Reiter said.

'Obvious attempt at fraud'

Michael Packer, of Marshall, Dennehey, Warner, Coleman & Goggin in Fort Lauderdale, said it was one of the most contentious cases he's handled.

"We felt that district court's ruling was correct and are even more pleased that the circuit court found it this way because, to us, this was an obvious attempt of insurance fraud," said Packer, who represented the insurer. "There was no doubt in anyone's mind that when he [Quintero] called Geico on May 25 he knew his boat was stolen and he realized he had screwed up in not renewing his policy or getting other insurance."

Packer said he felt the case offered a lesson for insurance litigators.

"From a policyholders' attorney standpoint, there needs to be more objectivity to the situation," Packer said. "I think attorneys, as officers of the court, have to sometimes swallow their ego and swallow their pride and recognize that their client has done something wrong. That's what we try to do when we represent insurance companies."