IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF LOUISIANA MONROE DIVISION HARRIET VINCENT AND DAMON VINCENT, NO. 3:17-CV-00442-RGJ-KLH Plaintiffs, vs. JUDGE ROBERT G. JAMES WRIGHT NATIONAL FLOOD INSURANCE COMPANY, et al., MAGISTRATE JUDGE KAREN L. HAYES Defendants. MOTION TO DISMISS PLAINTIFFS’ CLAIMS FOR BAD FAITH, STATUTORY PENALTIES PURSUANT TO LOUISIANA REVISED STATUTES 22:1893 AND 22:1973 AND COMPENSATORY DAMAGES AND MOTION TO DISMISS WRIGHT NATIONAL FLOOD INSURANCE SERVICES, LLC Defendants, Wright National Flood Insurance Services, LLC (“WNFIS”) and Wright National Flood Insurance Company (“Wright”), a Write-Your-Own Program (“WYO”) insurance carrier participating in the United States Government’s National Flood Insurance Program (“NFIP”), pursuant to the National Flood Insurance Act of 1968 (“NFIA”), as amended, 1 appearing in its “fiduciary” 2 capacity as the “fiscal agent of the United States,” 3 and pursuant to Federal Rule of Civil Procedure 12(b)(6), move for entry of an order dismissing Plaintiffs’ claims for bad faith, statutory penalties pursuant to Louisiana Revised Statutes 22:1893 and 22:1973, compensatory damages and all other state law claims and an order dismissing WNFIS as a defendant in this matter. 1 42 U.S.C. § 4001, et seq. 2 See 44 C.F.R. § 62.23(f). 3 42 U.S.C. § 4071(a)(1); Wright v. Allstate Ins. Co., 415 F.3d 384, 386 (5th Cir. 2005). Case 3:17-cv-00442-RGJ-KLH Document 6 Filed 03/30/17 Page 1 of 3 PageID #: 32 Plaintiffs’ claims for bad faith, statutory penalties pursuant to Louisiana Revised Statutes 22:1893 and 22:1973, compensatory damages and all other state law claims are preempted and barred under federal statutory, regulatory, and common law. Plaintiffs’ claims against WNFIS should be dismissed as the Standard Flood Insurance Policy was issued to the Plaintiffs by Wright in its capacity as a WYO Program insurance carrier and was not issued by WNFIS. WHEREFORE, for these reasons and for the reasons set forth in the Memorandum of Law in Support of the Motion to Dismiss filed contemporaneously herein, Wright National Flood Insurance Services, LLC and Wright National Flood Insurance Company respectfully request that the Court enter an Order dismissing all of the Plaintiffs’ claims, other than the claim for breach of the Standard Flood Insurance Policy filed against Wright National Flood Insurance Company. Dated: March 30, 2017 Respectfully submitted, PHELPS DUNBAR LLP BY: /s/ Arthur R. Kraatz Tessa Vorhaben (La. Bar #31293) Arthur R. Kraatz (La. Bar #35194) Canal Place | 365 Canal Street, Suite 2000 New Orleans, Louisiana 70130-6534 Telephone: 504-566-1311 Telecopier: 504-568-9130 Email: tessa.vorhaben@phelps.com arthur.kraatz@phelps.com ATTORNEYS FOR DEFENDANTS, WRIGHT NATIONAL FLOOD INSURANCE COMPANY AND WRIGHT NATIONAL FLOOD INSURANCE SERVICES, LLC Case 3:17-cv-00442-RGJ-KLH Document 6 Filed 03/30/17 Page 2 of 3 PageID #: 33 OF COUNSEL: /s/ Joel W. Morgan Joel W. Morgan (VSB #65761) FREEBORN & PETERS LLP 411 East Franklin Street, Suite 200 Richmond, VA 23219 Telephone: (804) 644-1300 Facsimile: (804) 644-1354 Email: jwmorgan@freeborn.com CERTIFICATE OF SERVICE I hereby certify that on March 30, 2017, a copy of the foregoing pleading was filed with the Clerk of Court by using CM/ECF system, which will send a notice of electronic filing to all participating counsel of record. /s/ Arthur R. Kraatz Arthur R. Kraatz Case 3:17-cv-00442-RGJ-KLH Document 6 Filed 03/30/17 Page 3 of 3 PageID #: 34 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF LOUISIANA MONROE DIVISION HARRIET VINCENT AND DAMON VINCENT, NO. 3:17-CV-00442-RGJ-KLH Plaintiffs, vs. JUDGE ROBERT G. JAMES WRIGHT NATIONAL FLOOD INSURANCE COMPANY, et al., MAGISTRATE JUDGE KAREN L. HAYES Defendants. DEFENDANTS’ MEMORANDUM OF LAW IN SUPPORT OF MOTION TO DISMISS PLAINTIFFS’ CLAIMS FOR BAD FAITH, STATUTORY PENALTIES PURSUANT TO LOUISIANA REVISED STATUTES 22:1893 AND 22:1973 AND COMPENSATORY DAMAGES AND MOTION TO DISMISS WRIGHT NATIONAL FLOOD INSURANCE SERVICES, LLC Defendants, Wright National Flood Insurance Services, LLC (“WNFIS”) and Wright National Flood Insurance Company (“Wright”), a Write-Your-Own Program (“WYO”) insurance carrier participating in the United States Government’s National Flood Insurance Program (“NFIP”), pursuant to the National Flood Insurance Act of 1968 (“NFIA”), as amended, 1 appearing in its “fiduciary” 2 capacity as the “fiscal agent of the United States,” 3 and provide this Memorandum of Law in Support of their Motion to Dismiss Plaintiffs’ claims for bad faith, statutory penalties pursuant to Louisiana Revised Statutes 22:1893 and 22:1973, compensatory damages and all other state law claims and Motion to Dismiss all claims against WNFIS. 1 42 U.S.C. § 4001, et seq. 2 See 44 C.F.R. § 62.23(f). 3 42 U.S.C. § 4071(a)(1); Wright v. Allstate Ins. Co., 415 F.3d 384, 386 (5th Cir. 2005). Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 1 of 10 PageID #: 35 2 Plaintiffs’ claims for bad faith, statutory penalties pursuant to Louisiana Revised Statutes 22:1893 and 22:1973, compensatory damages and all other state law claims are preempted and barred under federal statutory, regulatory, and common law. See Gallup v. Omaha Prop. & Cas. Ins., 434 F.3d 341, 344-45 (5th Cir. 2005) (dismissing Louisiana state law claims of bad faith breach of contract under Louisiana Civil Code Article 1997 and bad faith adjustment under Louisiana Revised Statute 22:1220); Howell-Douglas v. Fidelity Nat. Indem. Ins. Co., 24 F. Supp. 3d 579, 583 (E.D. La. 2014) (dismissing claims for statutory penalties pursuant to Louisiana state law); Berger v. National Flood Ins. Program, 2013 WL 499310, at *5 (E.D. La. Feb. 7, 2013) (dismissing state law claims under Louisiana Revised Statute 22:1973); Bercier v. Bernard, 2010 WL 4938657, at *4 (W.D. La. Nov. 29, 2010) (dismissing claims for state law statutory penalties and attorney’s fees); see also Wright v. Allstate Ins. Co., 415 F.3d 384, 390 (5th Cir. 2005); Newton v. Capital Assur. Co., 245 F.3d 1306, 1310-12 (11th Cir. 2001); West v. Harris, 573 F.2d 873, 881 (5th Cir. 1978). Plaintiffs’ claims for breach of the Standard Flood Insurance Policy against WNFIS fail because the Plaintiffs’ policy was issued by Wright in its capacity as a WYO program insurance carrier, and not by WNFIS. For the reasons set forth below, all of the Plaintiffs’ claims, other than the claim against Wright for breach of the Standard Flood Insurance Policy, should be dismissed. I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY The Plaintiffs allege that they were the “owners” of a flood insurance policy issued “by the defendants.” Plaintiffs’ Petition for Damages, at ¶ 2. Wright admits that while acting in its capacity as a WYO carrier, it issued Standard Flood Insurance Policy (“SFIP”) No. 17 1150334384 05 (the “Policy”) to Plaintiffs for their property located at 176 Timber Way, Monroe, Louisiana (the “Property”). Id.; see Declarations Page attached hereto as Exhibit 1. Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 2 of 10 PageID #: 36 3 Plaintiffs allege that the Property sustained damages from flooding on March 9, 2016. Petition, at ¶ 4. The Plaintiffs filed suit against Wright and WNFIS in the Fourth Judicial District Court for Ouachita Parish, Louisiana, alleging that the Defendants breached the Policy by failing to pay the amounts that Plaintiffs claim are due and owing under the SFIP. Id., at ¶¶ 13, 14. In addition to the damages sought for breach of contract, Plaintiffs also assert bad faith allegations and request an award of statutory penalties pursuant to Louisiana Revised Statutes 22:1893 and 22:1973 and compensatory damages. Id., at ¶¶ 13, 15, WHEREFORE. The Defendants removed the Plaintiffs’ action to this Court on March 23, 2017, as the United States district courts have original exclusive jurisdiction over claims arising under the SFIP. II. BACKGROUND OF THE NATIONAL FLOOD INSURANCE PROGRAM Congress created the NFIP pursuant to the NFIA, 42 U.S.C. § 4001, et seq. Battle v. Seibels Bruce Ins. Co., 288 F.3d 596, 598-600 (4th Cir. 2002) (discussing history and organization of the NFIP). The Director of the Federal Emergency Management Agency (“FEMA”) is charged with overseeing and implementing the NFIP. Id. Additionally, the Director of FEMA is statutorily authorized to promulgate regulations “for general terms and conditions of insurability which shall be applicable to properties eligible for flood insurance coverage.” 42 U.S.C. § 4013. The regulations also prescribe the methods by which approved losses under the NFIP may be adjusted and paid. 42 U.S.C. § 4019. Pursuant to FEMA regulations, “all policies issued under the NFIP must be issued using the terms and conditions of the [SFIP] found in 44 C.F.R. Part 61, Appendix A.” Battle, 288 F.3d at 599 (citing 44 C.F.R. §§ 61.4(b), 61.13(d), (e), 62.23(c)). In 1983, under the WYO Program, the Director of FEMA authorized the SFIP to be issued by private insurance companies, commonly referred to as WYO companies (e.g., Wright). Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 3 of 10 PageID #: 37 4 42 U.S.C. § 4071(a)(1); 44 C.F.R. § 62.23. The WYO companies issuing flood insurance under the NFIP arrange for the adjustment, settlement, payment, and defense of all claims arising from the policy. 44 C.F.R. § 62.23(d). Congress underwrites all operations of the NFIP, including claims adjustment, through the United States Treasury funds. 42 U.S.C. § 4017(d)(1). The federal government pays all flood insurance claims and reimburses WYO program insurers their costs, including defense costs, for the adjustment and payment of claims. Grissom v. Liberty Mut. Fire Ins. Co., 678 F.3d 397, 402 (5th Cir. 2012) (citing Campo v. Allstate Ins. Co., 562 F.3d 751, 754 (5th Cir. 2009)); 44 C.F.R. pt. 62, app. A., art. III(D)(1)-(2); see also Newton, 245 F.3d at 1312. Congress has conferred “rule-making power upon the agency created for carrying out its policy” to FEMA. 42 U.S.C. §§ 4013, 4017, 4019. Congress statutorily authorized FEMA to enter into “Arrangements” with private insurance companies that operate as the “fiscal agent of the United States.” 42 U.S.C. § 4071(a)(1). In effect, a suit against a WYO company is the functional equivalent of a suit against FEMA. Van Holt v. Liberty Mut. Ins. Co., 163 F.3d 161, 166-67 (3d Cir. 1998); see Shuford v. Fidelity Nat. Prop. & Cas. Ins. Co., 508 F.3d 1337, 1343 (11th Cir. 2007). Thus, a judgment against a WYO company constitutes a judgment against FEMA, and consequently, a direct charge on the United States Treasury. Shuford, 508 F.3d at 1343; Newton, 245 F.3d at 1311-12; Van Holt, 163 F.3d at 167; see Wright v. Allstate, 415 F.3d at 387. Federal law governs the interpretation of the provisions of the SFIP. Article IX of the SFIP provides: This policy and all disputes arising from the handling of any claim under the policy are governed exclusively by the flood insurance regulations issued by FEMA, the National Flood Insurance Act of 1968, as amended (42 U.S.C. §4001, et seq.), and Federal common law. Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 4 of 10 PageID #: 38 5 44 C.F.R. pt. 61, app. A(1), art. IX; see Wright v. Allstate, 415 F.3d at 390. As the U.S. Court of Appeals for the Fifth Circuit has stated: Since the flood insurance program is a child of Congress, conceived to achieve policies which are national in scope, and since the federal government participates extensively in the program both in a supervisory capacity and financially, it is clear that the interest in uniformity of decision present in this case mandates the application of federal law. West, 573 F.2d at 881; Wright v. Allstate, 415 F.3d at 390. III. ARGUMENT AND CITATION TO AUTHORITIES A. Standard for Dismissal To warrant dismissal of a complaint under Rule 12(b)(6) of the Federal Rules of Civil Procedure, the Court must be satisfied “‘that no relief could be granted under any set of facts that could be proved consistent with the allegations.’” In re Burzynski, 989 F.2d 733, 739 (5th Cir. 1993) (quoting Hishon v. King & Spalding, 467 U.S. 69, 73, 104 S. Ct. 2229, 2232 (1984)). In deciding a Rule 12(b)(6) motion to dismiss, a court must first be mindful of the liberal pleading standards under Rule 8, which require only “a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8. Thus, a court must take “the material allegations of the complaint” as admitted and liberally construe the complaint in favor of a plaintiff. Jenkins v. McKeithen, 395 U.S. 411, 421-22, 89 S. Ct. 1843, 1849 (1969). While Rule 8 does not require “detailed factual allegations,” a plaintiff must still provide “more than labels and conclusions” because “a formulaic recitation of the elements of a cause of action will not do.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555, 127 S. Ct. 1955, 1965 (2007) (citation omitted). Indeed, the legal framework of the complaint must be supported by factual allegations that “raise a right to relief above the speculative level.” Id. However, “‘when the allegations in a complaint . . . could not raise a claim of entitlement to relief,’” this defect Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 5 of 10 PageID #: 39 6 should be exposed at an early stage and the claim dismissed. Cuvillier v. Taylor, 503 F.3d 397, 401 (5th Cir. 2007) (quoting Twombly, 550 U.S. at 558, 127 S. Ct. at 1966). “When considering a Rule 12(b)(6) motion, a court may consider documents outside the complaint when they are: (1) attached to the motion; (2) referenced in the complaint; and (3) central to the plaintiff’s claims.” Slade v. Progressive Sec. Ins. Co., 2013 WL 12182957, at *4 (W.D. La. Feb. 4, 2013) (citing In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007) (holding that attaching insurance contracts to the defendants’ motion to dismiss did not serve to convert the motion to dismiss into a motion for summary judgment where the contracts were referred to in the complaints and were central to the plaintiffs’ claims)). Moreover, when exhibits to or referenced by a complaint contradict the allegations contained in the complaint, the exhibits control. See Hollingshead v. Aetna Health, Inc., 589 Fed. Appx. 732, 737 (5th Cir. 2014) (citing Associated Builders, Inc. v. Alabama Power Co., 505 F.2d 97, 100 (5th Cir. 1974)). “If the appended document, to be treated as part of the complaint for all purposes under Rule 10(c), Fed. R. Civ. P., reveals facts which foreclose recovery as a matter of law, dismissal is appropriate.” Associated Builders, 505 F.2d at 100. B. Plaintiffs’ Claims for Bad Faith, Statutory Penalties Pursuant Louisiana Revised Statutes 22:1893 and 22:1973 and Compensatory Damages are Preempted and Barred by Federal Law Defendants move for dismissal of Plaintiffs’ claims of bad faith and for statutory penalties pursuant to Louisiana Revised Statutes 22:1893 and 22:1973, compensatory damages and all other state law claims. Federal law controls breach of contract actions involving SFIPs. Wright v. FEMA, 913 F.2d 1566, 1570-71 (11th Cir. 1990); West, 573 F.2d at 881; see Wright v. Allstate, 415 F.3d at 390. Courts have consistently held that state law claims in a suit brought pursuant to a SFIP are preempted by federal law. Gallup, 434 F.3d at 344-45; Wright v. Allstate, Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 6 of 10 PageID #: 40 7 415 F.3d at 389-90 (citing C.E.R. 1988, Inc. v. Aetna Cas. & Sur. Co., 386 F.3d 263 (3d Cir. 2004) and Gibson v. Am. Bankers Ins. Co., 289 F.3d 943 (6th Cir. 2002)). The Plaintiffs are not entitled to recover such fees or damages or any such related expenses under federal law in connection with a breach of contract claim under a SFIP. See Bercier, 2010 WL 4938657, at *4- 5. The Plaintiffs’ recovery under the SFIP is limited to the cost to repair or replace property damaged by “direct physical loss by or from flood,” debris removal, loss avoidance measures and Increased Cost of Compliance. 44 C.F.R. pt. 61, app. A(1), art. III; see Monistere v. State Farm Fire & Cas. Co., 559 F.3d 390, 393 (5th Cir. 2009). Consequently, there is no basis for recovery of statutory penalties pursuant to Louisiana Revised Statutes 22:1893 and 22:1973, compensatory damages or any other damages under state law in cases involving a dispute under the NFIP. See Gallup, 434 F.3d at 344-45; Wright v. Allstate, 415 F.3d at 389-90; Bercier, 2010 WL 4938657, at *4; see Adams v. State Farm Fire and Cas. Co., 1996 WL 592734, at *2 (E.D. La Oct. 10, 1996) (citing West, 573 F.2d at 881-82); Hanover Bldg. Materials, Inc. v. Guiffrida, 748 F.2d 1011, 1015 (5th Cir. 1984). The Fifth Circuit’s decision in Gallup is controlling. The Plaintiff in Gallup advanced claims against the WYO carrier for an alleged breach of the SFIP, breach of the duty of good faith and fair dealing under federal common law, bad faith breach of contract under Louisiana Civil Code Article 1997 and bad faith adjustment under Louisiana Revised Statute 22:1220. 434 F.3d at 343. The District Court granted the defendant’s Motion to Dismiss the plaintiffs’ claims under federal common law and Louisiana Revised Statute 22:1220 (on grounds other than preemption), but denied the motion as to the plaintiffs’ claim under Article 1997. Id. at 343-44. The District Court held that FEMA was not authorized by Congress to preempt the application of state laws to extra-contractual claims under the SFIP. Id. The ruling was appealed to the United Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 7 of 10 PageID #: 41 8 States Court of Appeals for the Fifth Circuit. Id. at 344. The Fifth Circuit, relying upon its decision in Wright v. Allstate, and citing Article IX of the SFIP, held that state law tort claims are preempted by the NFIA and that the NFIA provided FEMA with the authority to promulgate regulations to that effect. Id. at 344-45. Moreover, no provision within the NFIA allows for an award of statutory penalties or compensatory damages. The SFIP provides that coverage only extends to “direct physical loss by or from flood. . . .” 44 C.F.R pt. 61, app. A(1), art. III(A); see Monistere, 559 F.3d at 393. Congress only extended flood insurance coverage under the NFIP for “loss resulting from physical damage to or loss of real property or personal property related thereto. . . .” 42 U.S.C. § 4011; see Monistere, 559 F.3d at 393; see also Perdido Sun Condo. Ass’n v. Nationwide Mut. Ins. Co., 2007 WL 2565990, at *6 (N.D. Fla. Aug. 30, 2007). “‘[T]he type of loss insured under the SFIP does not include the kind of economic loss claimed by appellant under the rubric of “consequential damages.”’” Perdido Sun, 2007 WL 2565990, at *6 (quoting Atlas Pallet, Inc. v. Gallagher, 725 F.2d 131, 139 (1st Cir. 1984)); Linblad v. Nationwide Mut. Ins. Co., 2014 WL 6895775, at *6-7 (D.N.J. Dec. 4, 2014). The Atlas Pallet court concluded “that the SFIP only covers physical damage to the insured building.” 725 F.2d at 139. Likewise, the Perdido Sun court found that the plaintiff’s demand for consequential damages, including attorney’s fees, was improper under the SFIP. 2007 WL 2565990, at *6. C. Plaintiffs’ Claims Against WNFIS Should Be Dismissed Because the SFIP Was Issued by Wright as a WYO Carrier The Petition filed by the Plaintiffs allege a claim under the Policy issued to the Plaintiffs. The Policy was issued by Wright as a WYO program insurance carrier participating in the NFIP. See Exhibit 1. As the Declarations Page is part of the Policy referenced in the Petition, and the Policy is central to the Plaintiffs’ recovery for breach of the SFIP, the inclusion of the Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 8 of 10 PageID #: 42 9 Declarations Page does not convert this Motion to Dismiss under Rule 12(b)(6) into a Motion for Summary Judgment under Rule 56. Slade, 2013 WL 12182957, at *4. The Declarations Page attached as Exhibit 1 establishes that the Policy was issued by Wright and not WNFIS. WNFIS does not issue SFIPs and has been improperly named as a defendant in this action. Because the only alleged relationship between WNFIS and the Plaintiffs is directly contradicted by the Declarations Page, the Declarations Page controls and the claims against WNFIS should be dismissed. See Associated Builders, 505 F.2d at 100. The Plaintiffs only claims lie against Wright for the alleged breach of the SFIP. IV. CONCLUSION For the aforesaid reasons, Wright National Flood Insurance Company and Wright National Flood Insurance Services, LLC, respectfully pray that the Court enter an Order dismissing the Plaintiffs’ claims for bad faith, statutory penalties pursuant to Louisiana Revised Statutes 22:1893 and 22:1973, compensatory damages and all other state law claims and an Order dismissing all of the Plaintiffs’ claims against Wright National Flood Insurance Services, LLC. Dated: March 30, 2017 Respectfully submitted, PHELPS DUNBAR LLP BY: /s/ Arthur R. Kraatz Tessa Vorhaben (La. Bar #31293) Arthur R. Kraatz (La. Bar #35194) Canal Place | 365 Canal Street, Suite 2000 New Orleans, Louisiana 70130-6534 Telephone: 504-566-1311 Telecopier: 504-568-9130 Email: tessa.vorhaben@phelps.com arthur.kraatz@phelps.com Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 9 of 10 PageID #: 43 10 ATTORNEYS FOR DEFENDANTS, WRIGHT NATIONAL FLOOD INSURANCE COMPANY AND WRIGHT NATIONAL FLOOD INSURANCE SERVICES, LLC OF COUNSEL: /s/ Joel W. Morgan Joel W. Morgan (VSB #65761) FREEBORN & PETERS LLP 411 East Franklin Street, Suite 200 Richmond, VA 23219 Telephone: (804) 644-1300 Facsimile: (804) 644-1354 Email: jwmorgan@freeborn.com CERTIFICATE OF SERVICE I hereby certify that on March 30, 2017, a copy of the foregoing pleading was filed with the Clerk of Court by using CM/ECF system, which will send a notice of electronic filing to all participating counsel of record. /s/ Arthur R. Kraatz Arthur R. Kraatz Case 3:17-cv-00442-RGJ-KLH Document 6-1 Filed 03/30/17 Page 10 of 10 PageID #: 44 ! ! 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