Most first-party insurance lawsuits are accompanied by a claim for attorneys’ fees based on section 627.428, Florida Statutes. The operative language of this statute has been part of Florida law for over a century, and the cases interpreting that language are legion. On September 29, 2016, the Florida Supreme Court issued its decision in Johnson v. Omega Insurance Co.,1 which addressed the following issue: “Whether an insured’s recovery of attorneys’ fees under section 627.428, Florida Statutes, requires that there be bad faith on the part of an insurance company in the denial of a valid claim, or simply an incorrect denial of benefits.”