The Florida Supreme Court recently clarified the state of Florida law with respect to some of the most common tenants of policy interpretation, in response to questions certified by the Eleventh Circuit. Washington Nat’l Ins. Corp. v. Ruderman, No. SC12-323 (Fla. Jul. 3, 2013). In the case below – Ruderman ex rel. Schwartz v. Washington National Insurance Corporation, 671 F.3d 1208 (11th Cir. 2012) – the Eleventh Circuit sought clarification as to: (i) what constitutes an ambiguity in the language of an insurance policy and (ii) how such ambiguities are to be resolved, including the rules with respect to the examination of extrinsic evidence. In response, the Florida Supreme Court held that an ambiguity is present when more than one reasonable interpretation of the language exists and leads to conflicting coverage results. The Court reaffirmed that Florida continues to liberally construe such ambiguities in favor of coverage for the policyholder. Unlike many other states, however, the Court confirmed that Florida continues to exclude consideration of extrinsic evidence in determining the existence of any ambiguity.