In Pierce v. Reynolds, Civil Action No. 1:06CV363 LTS-JMR, 2006 WL 1328899 (S.D. Miss. May 15, 2006), the United States Court for the Southern District of Mississippi granted a motion to remand regarding a compensation action stemming from hurricane damage.

Irvin Pierce bought an Allstate homeowners policy from agent Tim Reynolds. Reynolds advised Pierce that he did not need flood insurance. Relying on Reynolds's recommendation, Pierce did not buy flood coverage. Pierce sustained damage from Hurricane Katrina and filed this suit against Reynolds, alleging that Reynolds offered negligent representations that he relied upon and suffered damage.