To shed a little light on insurance coverage issues that most likely will arise in the wake of Hurricane Katrina, we are revisiting two homeowners cases from the 1960s that were litigated following Hurricane Betsy.

 In a Louisiana case, Morehead v. Allstate Ins. Co., 406 F.2d 122 (5th Cir. 1969), the court found that a house was destroyed by flood and not windstorm.

 Arthur Morehead's frame dwelling was destroyed in Hurricane Betsy. He contended that windstorm, a covered peril, was the cause of his loss. His insurer, Allstate, pointed to a policy exclusion that stated that the insurer would not pay for "loss caused by, resulting from, contributed to or aggravated by…flood, surface water, waves, tidal water or tidal wave, overflow of streams or other bodies of water" to deny the claim. HO 00 03 10 00.]