Bank of NH v. FEMA

CourtDistrict Court, D. New Hampshire
DecidedFebruary 16, 1996
DocketCV-95-254-JD
StatusPublished

This text of Bank of NH v. FEMA (Bank of NH v. FEMA) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of NH v. FEMA, (D.N.H. 1996).

Opinion

Bank of NH v. FEMA CV-95-254-JD 02/16/96 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Bank of New Hampshire

v. Civil NO. 95-254-JD

Federal Emergency Management Agency, et al.

O R D E R

The plaintiff. Bank of New Hampshire, brought this action

asserting breach of contract, negligence, and estoppel and

seeking, inter alia, a declaration regarding the defendants'

obligations under a flood insurance policy.1 Before the court

are the defendants' motions for summary judgment (document nos. 6

and 12) .2

1The plaintiff alleged in its complaint that jurisdiction was conferred under the Declaratory Judgment Act and 28 U.S.C. § 1346, the United States' waiver of sovereign immunity for actions sounding in contract, id. § 1346(a) (2), and actions sounding in tort, id. § 1346(b). Without amending its complaint, the plaintiff also has argued that jurisdiction is predicated on section 1341 of the National Flood Insurance Act of 1968, 42 U.S.C. § 4072.

2By order of January 9, 1996, the court expressed its intention to convert the pending motions to dismiss into motions for summary judgment. As neither party objected to the court's stated intention, the court considers the current motions under Rule 56. Background3

A. The Flood

The plaintiff is the first mortgagee of property owned by

Robert P. Mitchell, Sr. and Kathleen Greer (the "homeowners") in

Barnstead, New Hampshire. The property is covered by a standard

flood insurance policy ("SFIP") issued by the defendants.4

According to the defendants, the policy was scheduled to

lapse on October 27, 1993. The defendants have submitted

evidence indicating that a renewal notice was sent to the

plaintiff, the homeowners, and the homeowners' insurance company

forty-five days prior to the policy's expiration date, and that a

notice of expiration was sent to these parties on October 27,

1993. Declaration of James S.P. Shortley 5 3. The plaintiff

3Unless otherwise noted, the court's recitation of the facts relevant to the instant motion are either not in dispute or have been alleged by the plaintiff.

4By executive order, the Federal Emergency Management Agency ("FEMA") has been charged with administration of the National Flood Insurance Program ("NFIP"), which originally was created in 1968 as a joint venture between the federal government and the private insurance industry. See 42 U.S.C.A. § 4001 (West 1994). Today, FEMA issues and services NFIP flood insurance plans through one of its subdivisions, the National Insurance Agency ("NIA"). As authorized by statute, the NIA contracts with private servicing agents, including Computer Science Corporation, which serviced the policy in guestion prior to October 1993, and defendant National Con-Serv, which serviced the policy thereafter. See 42 U.S.C.A. § 4081 (West 1994); 44 C.F.R. § 62.3 (1993 & 1994) .

2 alleges that it received neither of these notices. Complaint 55

17-18 .

On or about October 25, 1993, the homeowners informed the

plaintiff that a renewal premium was due on the policy. Id. 5

13. Constance Hamel, a customer service representative for the

plaintiff, subsequently prepared a treasurer's check dated

November 4, 1993, and sent it via first-class mail to NFIP as

payment for the premium. Affidavit of Constance Hamel, October

3, 1995 ("Second Hamel Affidavit") 5 4.

On January 21, 1994, a flood damaged the homeowners' real

and personal property. Hamel was informed of the flood and

contacted Laurie Michie, an NFIP assistant project director, who

notified Hamel that no renewal payment had been received and that

the policy had lapsed. Affidavit of Constance Hamel, August 22,

1995 ("First Hamel Affidavit") 55 3-4. Michie suggested that the

plaintiff issue a second check and send a letter of appeal to the

NFIP. Id. 5 4. On January 27, 1994, Hamel sent NFIP a copy of

the treasurer's check dated November 4, 1993. In an accompanying

letter Hamel again requested coverage under the policy and

suggested that the original copy of the check had been lost in

the mail. On February 9, 1994, Michie contacted Hamel,

requesting additional information about the renewal payment and

informing Hamel that NFIP was sending a new application form to

3 the homeowners' insurance agent. Hamel Affidavit 5 5.5 There is

no indication in the record that the defendants reimbursed the

homeowners or took further action on the request for coverage

under the policy.

The homeowners filed a state court action against the

plaintiff seeking to recover damages resulting from the flood and

from the cancellation of the policy. The plaintiff subsequently

filed the instant action to determine the existence of coverage

B. The Policy

The policy relevant to this action, which is published at 44

C.F.R. P t . 61 A p p . A(l) (1993), names the homeowners as insured

parties and the plaintiff as a mortgagee.6 Article VIII,

paragraph G governs renewal of the policy:

The term of this policy commences on its inception date and ends on its expiration date . . . . We are under

5According to the defendants, a "subsequent policy was established" on the property, with coverage beginning on January 30, 1994. Shortley Affidavit 5 6.

^Although the plaintiff alleged in its complaint that it is a named insured under the policy, its subsequent submissions indicate that it is a named mortgagee. The court notes that the policy expressly insures both named beneficiaries and "[a]ny mortgagee . . . named in the application and declaration page." SFIP A r t . I .

4 no obligation to send you7 any renewal notice or other notice that your policy term is coming to an end and the receipt of any such notice by you shall not be deemed to be a waiver of this provision on our part.

This policy shall not be renewed and the coverage provided by it shall not continue into any successive policy term unless the renewal premium payment is received by us at the office of the NFIP within 30 days of the expiration date of this policy . . . . If the renewal premium payment is mailed by certified mail to the NFIP prior to the expiration date, it shall be deemed to have been received within the reguired 30 days. . . . In all other cases, this policy shall terminate as of the expiration date of the last policy term for which the premium payment was timely received at the office of the NFIP, and in that event, we shall not be obligated to provide you with any cancellation, termination, policy lapse, or policy renewal notice . . .; provided, however, with respect to any mortgagee (or trustee) named in the declarations form attached to this policy, this insurance shall continue in force only for the benefit of such mortgagee (or trustee) for thirty days after written notice to the mortgagee (or trustee) of termination of this policy, and shall then terminate.

Paragraph 0 tracks the terms of paragraph G as they relate to

mortgagees:

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