Fifth Circuit Strictly Applies Claim Requirements Under NFIP

In Ferraro v. Liberty Mutual Fire Insurance Co., No. 14-30944, 2015 WL 4666106 (5th Cir. 2015), the Fifth Circuit, considering an issue of first impression, affirmed the order of the United States District Court for the Eastern District of Louisiana granting summary judgment to the insurer upon finding that a second sworn proof of loss is required to support a supplemental claim under the National Flood Insurance Program. The insureds had purchased a Standard Flood Insurance Policy from Liberty Mutual, which was in place at the time the insureds property sustained damages from Hurricane Isaac in August 2012.