Daniel Oliveras v. Liberty Mutual Fire Insurance Company

CourtDistrict Court, M.D. Florida
DecidedFebruary 9, 2026
Docket6:25-cv-02144
StatusUnknown

This text of Daniel Oliveras v. Liberty Mutual Fire Insurance Company (Daniel Oliveras v. Liberty Mutual Fire Insurance Company) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Daniel Oliveras v. Liberty Mutual Fire Insurance Company, (M.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA □ ORLANDO DIVISION DANIEL OLIVERAS, Plaintiff, Vv. Case No. 6:25-ev-2144-JA-NWH LIBERTY MUTUAL FIRE INSURANCE COMPANY, Defendant.

ORDER This case is before the Court on Defendant’s motion to dismiss and alternative motion to strike (Doc. 6) and Plaintiffs response (Doc. 19). Based on the Court’s review of the parties’ submissions, the motion must be denied. I. BACKGROUND Plaintiff, Daniel Oliveras, obtained property insurance through Defendant, Liberty Mutual Fire Insurance Company, to cover real property located in Orlando, Florida. (Doc. 1-1 at 1). The property sustained damage during an October 2024 hurricane, which Plaintiff timely reported to Liberty Mutual. Ud. at 2). Liberty Mutual allegedly failed to adjust the claim in accordance with the terms of Plaintiffs policy. Ud.). Plaintiff then brought this action in state court against Liberty Mutual for breach of contract (Count J) and for a declaratory judgment under the Florida Declaratory Judgment Act,

§§ 86.011 et seq., Fla. Stat. (Count II). Liberty Mutual removed this case pursuant to 28 U.S.C. § 1441, invoking this Court’s diversity jurisdiction. (Doc. 1). Liberty Mutual then answered Count I of the complaint, (Doc. 5), and simultaneously filed a motion to dismiss and alternative motion to strike Count II, (Doc. 6), arguing that Count II is redundant to Count I. Il. LEGAL STANDARDS “A pleading that states a claim for relief must contain ...a short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). “[D]etailed factual allegations” are not required, but “[a] pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a

cause of action will not do.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007)). “To survive a [Rule 12(b)(6)] motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.” Id. (quoting Twombly, 550 U.S. at 570). In considering a Rule 12(b)(6) motion to dismiss, a court limits its “consideration to the well-pleaded factual allegations, documents central to or referenced in the complaint, and matters judicially noticed.” LaGrasta v. First Union Sec., Inc., 358 F.3d 840, 845 (11th Cir. 2004).

III. DISCUSSION A. Timeliness of the Motion to Dismiss The Court must first address the propriety of the filing of Liberty Mutual’s motion. In the Eleventh Circuit, “[a]n [a]nswer filed contemporaneously with the filing of a [m]otion to [d]ismiss renders the motion moot and makes it ‘procedurally impossible for the Court to rule on the motion to dismiss.” Smith

v. Bank of Am., N.A., No. 2:11-cv-676-FtM, 2014 WL 8970382, at *9 (M.D. Fla. Mar. 6, 2014) (quoting Brisk v. City of Miami Beach, 709 F. Supp. 1146, 1147 (S.D. Fla. 1989)). A motion to dismiss under Rule 12(b) “must be made before pleading.” Fed. R. Civ. P. 12(b). For this reason, “a majority of federal courts have determined that a Rule 12(b) motion to dismiss tolls the time for a defendant to answer, even when not all the counts in the complaint are the subject of the Rule 12(b) motion to dismiss.” Jacques v. First Liberty Ins. Corp., No. 8:16-cv-1240-T-23TBM, 2016 WL 3221082, at *1n.1 (M.D. Fla. June 9, 2016) (collecting cases); see also Fed. R. Civ. P. 12(a)(4)(A) (explaining that a Rule 12 motion tolls the time for the moving party to serve a responsive pleading). District court responses to a simultaneously filed answer and motion to dismiss have not been uniform. Some district courts “routinely deny motions to dismiss as moot which are filed simultaneously with or after an answer is filed.” Walker v. Mead, No. 6:18-cv-1894-Orl, 2014 WL 2778162, at *3 (M.D. Fla. June 18, 2014) (collecting cases). Others have converted untimely Rule 12(b)(6)

motions to dismiss into Rule 12(c) motions for judgment on the pleadings. See, e.g., Thornton v. City of St. Petersburg, No. 8:11-cv-2765, 2012 WL 2087434, at *2 (M.D. Fla. Jun. 8, 2012); Alilin v. State Farm Mut. Auto. Ins. Co., No. 6:14- ev-1183-Orl, 2014 WL 7734262, at *3 (M.D. Fla. Jan. 30, 2014); Byron v. Natl R.R. Passenger Corp., No. 6:14-cv-1370-Orl, 2015 WL 13792224, at *2 (M.D. Fla. Jan. 14, 2015). Still others have struck the earlier-filed answer and allowed the motion to dismiss. See, e.g., Askan v. FARO Techs., Inc., No. 6:23-cv-920, 2024 WL 1773278, at *1 (M.D. Fla. Apr. 24, 2024). Here, Liberty Mutual simultaneously filed an answer to Count I—without answering Count IJ—and a motion to dismiss Count II. The Court assumes Liberty Mutual was acting in good faith and that it believed it was expediting the case by filing a partial answer to the complaint while its partial motion to dismiss was pending. But the pleadings are considered closed “when a complaint and answer have been filed.” Lillian B. ex rel. Brown v. Gwinnett Cnty. Sch. Dist., 631 F. App’x 851, 853 (11th Cir. 2015).1 And once the pleadings are closed, “lajn allegation ...is admitted if a responsive pleading is required and the allegation is not denied.” Fed. R. Civ. P. 8(b)(6). To discourage piecemeal adjudication, the federal rules provide no mechanism for a defendant to file a

the Eleventh Circuit, “unpublished decisions .. . bind no one,” Ray v. McCullough Payne & Haan, LLC, 838 F.3d 1107, 1109 (11th Cir. 2016), but “may be cited as persuasive authority,” 11th Cir. R. 36-2.

second answer if a partial motion to dismiss—filed simultaneously with a partial answer—is ultimately denied. However, district courts possess “broad discretion ... in managing their cases.” Chrysler Int’l Corp. v. Chemaly, 280 F.3d 1358, 1860 (11th Cir. 2002). And “[s]triking pleadings under Rule 12(f) is a matter committed to the court’s sound discretion.” Alms v. Luminar Techs., Inc., No. 6:23-cv-982, 2025 WL 1531146, at *1 (M.D. Fla. May 29, 2025) (citing McCorstin v. U.S. Dep’t of Lab., 630 F.2d 242, 244 (5th Cir. 1980)).2 Accordingly, the Court—noting that Plaintiff did not raise this issue in his response to the motion to dismiss and finding that he would not be prejudiced—will exercise its discretion to strike the answer, address the merits of the motion to dismiss below, and afford Liberty Mutual an opportunity to file a responsive pleading to the complaint in its entirety after disposition of the motion to dismiss. B. Declaratory Judgment Plaintiff, having initially filed this case in Florida circuit court, brings Count II under the Florida Declaratory Judgment Act. §§ 86.011 et seq., Fla. Stat. (Doc. 1-1 at 3-7). However, “Florida’s Declaratory Judgment Act...isa procedural mechanism that confers subject matter jurisdiction on Florida’s

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Daniel Oliveras v. Liberty Mutual Fire Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniel-oliveras-v-liberty-mutual-fire-insurance-company-flmd-2026.