Waterline Villas and Marina Condo Association, Inc. v. Wright National Flood Insurance Company

CourtDistrict Court, M.D. Florida
DecidedJuly 10, 2026
Docket8:26-cv-00040
StatusUnknown

This text of Waterline Villas and Marina Condo Association, Inc. v. Wright National Flood Insurance Company (Waterline Villas and Marina Condo Association, Inc. v. Wright National Flood 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
Waterline Villas and Marina Condo Association, Inc. v. Wright National Flood Insurance Company, (M.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

WATERLINE VILLAS AND MARINA CONDO ASSOCIATION, INC.,

Plaintiff,

v. Case No. 8:26-cv-40-KKM-SPF

WRIGHT NATIONAL FLOOD INSURANCE COMPANY,

Defendant. ___________________________________ ORDER Waterline Villas and Marina Condo Association, Inc., sues Wright National Flood Insurance Company, alleging that the defendant breached the parties’ flood insurance policy by retroactively altering the property description and denying coverage, or in the alternative, that the defendant negligently misrepresented the policy and unjustly enriched itself as a result. See Am. Compl. (Doc. 6). Wright moves to dismiss the breach of contract claim as time barred and the state-law claims as preempted by federal law. See MTD (Doc. 21). Waterline opposes. Resp. (Doc. 22). Wright replies in support of its motion. Reply (Doc. 25). For the reasons below, I grant the motion. I. BACKGROUND Wright National Flood Insurance Company is a Write-Your-Own (WYO)

Program Carrier1 offering flood insurance under the National Flood Insurance Act (NFIA). Am. Compl. ¶ 6. In 2024, Wright issued a Standard Flood Insurance Policy (SFIP) for Waterline’s property under Policy No. 09115210131703. Id. ¶ 8; see also Doc. (6-1).

In September 2024, the insured property suffered losses because of Hurricane Helene. Am. Compl. ¶ 11. Waterline reported the losses to Wright and submitted a claim under the Policy. Id. ¶¶ 12–13. On January 3, 2025, Wright issued a letter denying coverage for part of the claim. Id. ¶ 15; see also

Denial Letter (Doc. 21-4). It “premis[ed] its denial on the allegation that the Building was elevated.” Am. Compl. ¶ 15. On January 16, 2025, Wright “issued an endorsement purporting to retroactively modify [the Policy] to describe the number of floors as Two Floors

and modifying the Property Description to ‘[e]levated with enclosure on posts/piles/piers.’ ” Id. ¶ 16. The endorsement “materially reduce[d] the

1 The Federal Emergency Management Agency (FEMA) created the WYO program in 1983 to allow private insurers to offer Standard Flood Insurance Policies through the National Flood Insurance Program (NFIP). See Hairston v. Travelers Cas. & Sur. Co., 232 F.3d 1348, 1349 n.1 (11th Cir. 2000). “[A]ll claims and expenses [for these policies] are paid out of the National Flood Insurance Fund in the U.S. Treasury.” Sanz v. U.S. Sec. Ins. Co., 328 F.3d 1314, 1316 n.1 (11th Cir. 2003) (per curiam). coverage afforded under the [P]olicy” due to coverage limitations for damage below the lowest elevated floor. Id. ¶ 17.

On January 7, 2026, Waterline filed this suit invoking federal question jurisdiction under 28 U.S.C. § 1331 because the action arises under the NFIA. See Compl. (Doc. 1); Am. Compl. ¶ 4. It brings claims against Wright for breach of contract, negligent misrepresentation, and unjust enrichment. Am. Compl.

¶¶ 23–24, 35, 45. Wright moves to dismiss the breach of contract claim as time barred and the two state-law claims as preempted by federal law. See MTD. Wright attaches copies of the January 3, 2024 denial letter, (Doc. 21-4), the SFIP dwelling form, (Doc. 21-3), the amended Policy declarations page, (Doc.

21-2), and a declaration of Wright’s Litigation Manager, Sarah Brandeberry, (Doc. 21-1). For the reasons below, I grant the motion. II. LEGAL STANDARD Federal Rule of Civil Procedure 8(a)(2) requires “a short and plain

statement of the claim showing that the pleader is entitled to relief.” This pleading standard “does not require ‘detailed factual allegations,’ but it demands more than an unadorned, the defendant-unlawfully-harmed-me accusation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp.

v. Twombly, 550 U.S. 544, 555 (2007)). “A pleading that offers ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action will not do.’ ” Id. (quoting Twombly, 550 U.S. at 555). “Nor does a complaint suffice if it tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’ ” Id. (quoting Twombly, 550 U.S. at 557).

“To survive a motion to dismiss” under Rule 12(b)(6), a plaintiff must plead sufficient facts to state a claim that is “plausible on its face.” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 555). A claim is facially plausible when a “plaintiff pleads factual content that allows the court to draw the

reasonable inference that the defendant is liable for the misconduct alleged.” Id. The complaint’s factual allegations are accepted “as true” and construed “in the light most favorable to the plaintiff.” Pielage v. McConnell, 516 F.3d 1282, 1284 (11th Cir. 2008). Consideration is limited “to the well-pleaded factual

allegations, documents central to or referenced in the complaint, and matters judicially noticed.” La Grasta v. First Union Sec., Inc., 358 F.3d 840, 845 (11th Cir. 2004), abrogated on other grounds by Twombly, 550 U.S. at 544. III. ANALYSIS

Wright moves to dismiss Waterline’s breach of contract claim as barred by the one-year statute of limitations provided in 42 U.S.C. § 4072 and the SFIP itself. MTD at 9–15. According to Wright, because Waterline “filed this action on January 7, 2026, over one year after Wright sent the January 3, 2025

Denial Letter,” the “claim for breach of the SFIP is barred by 42 U.S.C. § 4072 and 44 C.F.R. Part 61, Appendix A(3), Article VIII(O).” Id. at 15. As for the remaining state-law negligent misrepresentation and unjust enrichment claims, Wright moves to dismiss them as preempted by federal law. Id. at 16– 18. Waterline argues in response that Wright’s motion should be stricken for

relying upon material outside the complaint, and in the alternative, that equitable tolling salvages the breach of contract claim. Resp. at 4–5, 7. Waterline also argues that the state-law claims are not preempted because they arise from the procurement, rather than the handling, of the Policy. Resp.

at 5–7. I agree with Wright that Waterline’s breach of contract claim is time barred and that the remaining state-law claims are preempted by federal law. A. Incorporation by Reference At the outset, Waterline asserts that Wright’s motion is noncompliant

because it attaches documents outside the four corners of the complaint. Resp. at 4. Waterline argues that the motion “should be stricken” because Wright “relies upon the purported testimony of Sarah Brandeberry” and “additional materials not included in [the] Complaint.” Id. Waterline fails to fully

appreciate the incorporation by reference doctrine. See id. (“Defendant’s Motion is not saved by the alleged ‘incorporation by reference’ rule.”) I may consider the letter, dwelling form, and the Policy declarations page—but not the Brandeberry Declaration—under the incorporation-by-

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Waterline Villas and Marina Condo Association, Inc. v. Wright National Flood Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/waterline-villas-and-marina-condo-association-inc-v-wright-national-flmd-2026.