Insured who files late proof of loss cannot recover on homeowner policy, despite substantial compliance

Teresa Essa sued her homeowners' insurer, Pioneer State Mutual Insurance, after her home suffered severe water damage.  While she provided Pioneer State with virtually all of the information that would have been included in the insurer's "proof of loss" form, she was late filing the form itself (it is due within 60 days).  She argued that the insurer had waived strict compliance and that, in any event, she had "substantially complied" with the requirement, making it unjust to completely deny her any recovery.  In a decision that undoubtedly pleased Judge Henry Saad, he and two companions ruled that the insurer owed no duty to pay under the policy and could enforce the strict 60-day deadline.