Bilbe v. Belsom

JERRY E. SMITH, Circuit Judge:

Kathleen Bilbe’s house was destroyed by Hurricane Katrina. She submitted claims under a homeowners policy and a flood insurance policy issued by State Farm Fire and Casualty Company (“State Farm”). For the latter policy, State Farm paid Bilbe the policy limit of $96,400, but, after accounting for the deductible, paid only $1,466.27 under the homeowners policy, citing the Water Damage Exclusion.

Bilbe, appearing pro se in the district court and on appeal, sued State Farm and its agent in state court; the agent was dismissed, and State Farm removed to federal court,…