Holt v. State Farm Fire & Casualty Co.

CARL E. STEWART, Circuit Judge:

We are asked in this appeal to consider whether a prescriptive statute in Louisiana retroactively applies to Plaintiff-Appellee Eric Holt’s cause of action. Holt’s home in New Orleans, Louisiana suffered extensive fire damage in January 2007, and he sought to recover payment under his homeowners policy with Defendant-Appellant State Farm Fire & Casualty Company (State Farm). Dissatisfied with State Farm’s response to his claim, Holt filed suit against the insurer in February 2008. Between the time Holt’s cause of action arose in January 2007 and his lawsuit in…