The U.S. Court for the Southern District of Mississippi found flood exclusions in a homeowners policy to be unambiguous in Buente v. Allstate Ins. Co., No.1:05 CV 712 LTS JMR, 2006 WL 980784 (S.D. Miss. Apr. 12,, 2006).

Elmer and Alexa Buente's home was damaged in August 2005 during Hurricane Katrina. The Buentes claimed that the damage was partially caused by wind-driven rain and partially by rising water. They contended that their homeowners policy's flood exclusions were ambiguous and should not apply.