Responding to a question certified by the U.S. Court of Appeals for the Eleventh Circuit, the Supreme Court of Florida clarified that when policy language is ambiguous, courts should not consider extrinsic evidence to support an insurer's interpretation, but should resolve the ambiguity in favor of coverage. Washington Nat'l Ins. Corp. v. Ruderman, 2013 Fla. LEXIS 1388, No. SC12-323 (July 3, 2013). At issue was whether a clause that increased available limits for home health care in a life insurance policy applied only to available daily limits, or also to the lifetime maximum benefit amount. Finding the policy language ambiguous, the court held that the lower court was bound to accept a reasonable interpretation that the policyholder offered favoring greater coverage, without resort to evidence the insurer proffered to suggest a more restrictive construction. In so ruling, the court resolved a split in earlier Florida decisions, some of which had suggested that extrinsic evidence of the parties' intent could be considered in interpreting policy language, and that application of the rule of contra proferentem – automatically favoring the policyholder's interpretation of ambiguous language – should only be considered as a last resort.