Segal Radhi v. National Flood Insurance Program, et al.

Summary

The United States District Court for the Eastern District of Louisiana granted FEMA’s motion for summary judgment in a flood-insurance coverage dispute. The court held that the plaintiff’s claim concerning an April 2024 flood loss was barred by the one-year limitations period triggered by FEMA’s partial denial, and that the claim concerning a September 2024 loss failed because the plaintiff did not submit a timely signed and sworn proof of loss. The court dismissed the claims with prejudice, including any purported extra-contractual state-law claims as preempted.

Holdings

1. The August 20, 2024 partial-denial letter triggered the one-year limitations period under 42 U.S.C. § 4072 and the Standard Flood Insurance Policy. Because Radhi filed suit on September 8, 2025, more than one year later, her claim concerning the April 2024 loss was time-barred.
2. Radhi could not recover for the September 2024 loss because she failed to submit a timely signed and sworn proof of loss, an unalterable and unwaivable SFIP requirement.
3. To the extent Radhi alleged extra-contractual state-law claims, those claims were dismissed with prejudice as preempted by federal law.

Questions Presented

1. Whether Radhi's breach-of-contract claim concerning the April 2024 flood loss was barred because she filed suit more than one year after FEMA mailed a partial denial.
2. Whether Radhi's breach-of-contract claim concerning the September 2024 flood loss was barred by her failure to submit a timely signed and sworn proof of loss as required by the Standard Flood Insurance Policy.
3. Whether any asserted extra-contractual state-law claims were preempted by federal law governing the Standard Flood Insurance Policy.

Disposition

dismissed