Hurricane Preparedness for Florida Community Associations

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Florida community associations, including condominium associations, homeowners associations, and cooperatives, have significant legal and operational responsibilities when preparing for, responding to, and recovering from hurricanes. Boards of directors and community association managers (CAMs) must understand their statutory authority and exercise sound judgment to protect association property, residents, and operations.

With the start of the Atlantic hurricane season, associations should review and update their hurricane preparedness plans well in advance of any tropical weather threat.

Hurricane Preparedness Plan Requirements

Every community association should maintain a comprehensive, written hurricane preparedness plan that is reviewed and updated annually. The plan should be tailored to the community and should be accessible to board members, management, and key vendors.

Associations should carefully draft hurricane preparedness plans to avoid creating unrealistic expectations regarding resident safety, emergency response, or property protection. Plans should clearly communicate the association’s role and remind residents that they remain responsible for their own safety and personal property.

At a minimum, a hurricane preparedness plan should include:

Hurricane Plan Contents

  • Contact information for the board of directors and critical vendors, including legal counsel, landscapers, insurance agents, elevator vendors, and generator service providers
  • Site map identifying shut-off valves for gas, water, and sprinkler systems
  • Insurance claim forms and carrier contact information
  • Emergency powers and evacuation resolutions adopted by the board
  • Copies of all relevant contracts, vendor agreements, and insurance policies
  • Pre-storm photographs of buildings, trees, pumps, and common areas updated annually
  • Local emergency management contacts and resources
  • Documentation of association-owned property with photographs

Hurricane Emergency Checklist

  • Lift electronics and sensitive equipment off floors in common areas and offices
  • Deploy sandbags at low-lying or vulnerable entry points
  • Test generators and confirm fuel supply
  • Label all electric and water shut-off locations
  • Coordinate with elevator vendor regarding pre-storm shutdown procedures
  • Distribute hurricane preparedness instructions to residents
  • Post evacuation routes and shelter locations
  • Prepare hurricane supply kits, including a first-aid kit, flashlights, batteries, candles, a lighter, and a portable radio

Owners are responsible for their personal safety, evacuation decisions, and property. Associations should avoid making representations regarding resident safety or property protection that may not be feasible during emergency conditions.

Pre-Storm Preparation Checklist

The period before a hurricane is the most critical time for preparation.

  • Secure licensed vendors in advance, preferably with negotiated rates and clear contract terms. Consult legal counsel regarding vendor agreements and consider reserving the right to audit invoices and supporting documentation.
  • Confirm vendor roles and expectations under the disaster preparedness plan.
  • Meet with the association’s insurance agent before hurricane season to confirm claims procedures and review coverage limits, deductibles, and documentation requirements.
  • File a Right of Entry form with the county if your community has restricted access.
  • Ensure maintenance staff knows the location of shut-offs, emergency supplies, and tools, and understands response procedures for water, fire, and flood events.
  • Review emergency powers related to evacuation, board meetings, and emergency borrowing.
  • Conduct a financial review to ensure sufficient funds are available for insurance deductibles and immediate post-storm expenses and identify lines of credit that can be accessed if necessary.
  • Establish a timeline for tasks to be completed 72 hours, 48 hours, and 24 hours before anticipated landfall.

Hurricane Communication Planning

Effective communication is essential to protecting lives and property before, during, and after a storm.

  • Communicate the approved hurricane plan to residents
  • Establish an onsite command center or information distribution site
  • Post evacuation routes, fire escape routes, shelter information, and emergency contact information in common areas
  • Use multiple communication channels, including email, phone, text, and radio
  • Identify key community contacts, including CAMs, maintenance supervisors, and board leadership
  • Communicate early and frequently with residents and vendors as a storm approaches
  • Coordinate with legal counsel, property managers, county and state emergency management agencies, and the Federal Emergency Management Agency (FEMA)

FEMA Right of Entry Requirements

FEMA requires gated or restricted-access communities to have a current Right of Entry (ROE) form on file with the applicable county before damage assessments, debris removal, or recovery operations occur. Associations should verify ROE compliance before hurricane season begins.

Testing a Hurricane Preparedness Plan 

The best way to determine whether a plan will function effectively during an emergency is to test it. Review procedures with key personnel, verbally walk through the plan, and practice drills and hold debriefing sessions after exercises or actual storm events to verify areas for improvement.

Emergency Powers During a Hurricane Under Florida Law

Once the governor declares a state of emergency, Florida law grants community associations broad emergency powers under Florida Statutes Section 718.1265, Section 719.128, and Section 720.316.

These powers remain available based on the circumstances affecting the community and are not necessarily tied to the duration of the state of emergency declaration.

General Emergency Powers Include:

  • Conduct board and membership meetings with notice that is practicable under the circumstances
  • Relocate the association’s principal office or records
  • Implement the disaster preparedness plan
  • Turn utilities, elevators, security systems, and other infrastructure on or off as necessary
  • Borrow funds or levy special assessment without an owner vote
  • Determine which portions of the property are unsafe or unavailable for occupancy based on professional guidance

However, associations generally may not prohibit owners from accessing their property:

  • In connection with a sale, lease, or transfer of title
  • For habitability purposes unless a governmental order declares the property unsafe

Post-Hurricane Responsibilities

Immediately after the storm, associations should:

  • Assess damage to common elements and association property
  • Thoroughly document all damage with photographs and video before cleanup begins
  • Secure the property to prevent further damage or unauthorized access
  • File insurance claims promptly with all carriers

Associations should avoid rushing into remediation, repair, or public adjuster contracts. Even in emergency circumstances, legal and professional review can help prevent costly disputes and unfavorable contract terms.

Hurricane Preparedness Is a Legal Responsibility

Hurricane preparedness is both a legal obligation and a critical operational responsibility. Associations that proactively develop, maintain, and test their plans will be better positioned to protect residents, minimize damage, and accelerate recovery.

If you need assistance reviewing or drafting a hurricane preparedness plan, emergency resolution, or vendor agreement, contact Varnum’s Condominium and Homeowners Association Law Practice Team.

This advisory was originally published in June 2022.

Supreme Court Allows DHS to End Temporary Protected Status for Haiti and Syria

The U.S. Supreme Court has cleared the way for the Department of Homeland Security (DHS) to move forward with terminating Temporary Protected Status (TPS) for certain nationals of Haiti and Syria. The decision overturns lower court orders that had temporarily blocked the administration from ending the protections.

Temporary Protected Status is a humanitarian immigration program that allows eligible individuals from designated countries experiencing armed conflict, natural disasters or other extraordinary conditions to temporarily live and work in the United States. Similar TPS terminations have previously affected certain nationals of Afghanistan and Venezuela.

The Supreme Court’s decision may affect individuals who currently rely on TPS for immigration status or employment authorization. Individuals impacted by changes to TPS should evaluate their immigration options with qualified counsel, as eligibility for other immigration benefits or forms of relief will depend on individual circumstances.

If you have recently lost or expect to lose Temporary Protected Status, contact Varnum’s Immigration Practice Team. Depending on your circumstances, alternative immigration options may be available.

Federal Appeals Court Upholds Expanded Expedited Removal Policy

The U.S. Court of Appeals for the District of Columbia Circuit has ruled that the Department of Homeland Security (DHS) may continue enforcing its expanded expedited removal policy nationwide. Under the policy, noncitizens have the burden to carry documents confirming immigration status and/or at least two years of continuous presence in the country to avoid expedited removal. The ruling overturns a lower court decision that had blocked the policy.

The decision is expected to increase DHS’ inspection of documents and use of expedited removal proceedings. Noncitizens should make multiple copies of immigration status documents to keep at home, in cars and at work in case requested.

Please contact Varnum’s Immigration Practice Team with any questions or concerns.

Estate Planning Considerations for the FIRE Community: Protecting Your Independence and Legacy

The Financial Independence, Retire Early (FIRE) movement emphasizes living intentionally, maximizing savings, and creating the freedom to retire well before traditional retirement age. While much of the conversation centers on budgeting, investing, and lifestyle design, a crucial, but often overlooked, component is comprehensive estate planning.

Whether you plan to retire in your 30s, 40s, or 50s, early financial independence brings unique legal considerations. Creating an estate plan ensures your autonomy and intentions are preserved regardless of life’s uncertainties, allowing you to fully enjoy your hard-earned financial freedom.

Younger retirees often have a different asset structure than traditional retirees. You might hold a mix of taxable accounts, business interests, or alternative investments, some of which require specialized estate planning tools. For example, trusts can provide flexibility and control over how assets are managed and passed on, while avoiding probate court and protecting your privacy. Beneficiary designations also need to be carefully coordinated as part of your broader plan.

If you own a business or side venture, having succession plans and buy-sell agreements in place must be an essential part of your FIRE strategy. These documents coordinate with your estate plan to help manage transitions smoothly if you choose to sell, transfer, or wind down your enterprise.

Early retirees often plan for long, active retirements, but longevity brings exposure to incapacity. Creating durable powers of attorney and health care directives allows you to appoint trusted individuals to make financial and medical decisions on your behalf if you become unable to do so, ensuring those decisions align with your personal values and preferences.

Longevity also brings exposure to unforeseen risks and events. Your estate plan should include asset-protection strategies designed to preserve your independence and safeguard what you’ve built for future generations.

Finally, with a retirement that is expected to span decades, it is essential to regularly review and update your estate plan as your life evolves. Changes such as marriage, children, relocation, or changes in assets can affect how your plan operates, and these should be addressed regularly to keep your plan current and aligned with your goals.

The pursuit of a FIRE plan is about freedom, control and peace of mind. A well-crafted estate plan helps protect the assets you’ve built, support your loved ones and preserve your legacy. Consult with Varnum’s estate planning attorneys to ensure your plan aligns with your long-term goals and protects what matters most.

Expanded H-2A Access May Benefit Dairy Farmers

The Trump administration recently announced guidance that may expand access to the H-2A temporary agricultural worker program for dairy operations. Historically, the H-2A program has been limited to temporary or seasonal agricultural work, making it difficult for dairy producers with year-round labor needs to participate.

The new guidance from the Department of Homeland Security and Department of Labor signals greater flexibility for dairy employers seeking to utilize the H-2A program to address workforce challenges.

While additional implementation details are expected, dairy producers considering H-2A workers should be aware that the program continues to carry significant application, wage, housing and compliance requirements.

Varnum’s immigration attorneys are monitoring these developments and are available to assist employers in evaluating eligibility and navigating the H-2A process.

Medical Practice Succession Planning: Unlocking Value with ESOPs

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The Succession Planning Challenge Facing Medical Practices

Physician-owners of medical practices face increasing pressure to plan for ownership transitions. Nationally, 75 percent of business owners plan to exit within the next 10 years, yet only 34 percent have a documented and communicated succession plan, and fewer than one-third successfully sell their companies. The challenge is especially acute for medical practices, where the traditional partnership succession model is fading. Younger generations of physicians are less inclined to buy into partnerships, and hospital acquisitions of practices, which peaked during the COVID-19 era, have slowed.

Private equity has stepped aggressively into this void, completing approximately 500 medical practice acquisitions annually since 2020, often through management services organization (MSO) structures. Private equity transactions have become a significant succession planning and growth strategy for physician practices, but they often involve changes to governance structures, physician autonomy, and financial objectives that physician-owners should carefully evaluate.

An Employee Stock Ownership Plan (ESOP) is another ownership transition option for physician-owners evaluating succession strategies. Because ESOP transactions can use many of the same economic features as private equity, including compensation adjustments, and bank financing, an ESOP may be a viable succession planning alternative to private equity. The two structures share certain financial and transactional characteristics but differ in areas such as ownership, governance, tax treatment, and long-term objectives.

What Is an ESOP for a Medical Practice and How Does It Work?

An ESOP is a qualified retirement plan that invests primarily in employer stock and is administered by a trustee acting as a fiduciary for plan participants. It functions as both an employee benefit plan and a corporate finance tool, creating an internal market for shares of the practice.

In a leveraged ESOP transaction, physician-owners sell all or part of their equity while allowing the practice to continue operating independently under an employee ownership structure. The ESOP borrows funds to purchase shares from the current owners, and the resulting debt is repaid with tax-deductible company contributions, effectively using pre-tax dollars to retire acquisition debt. Employees receive allocations of shares over time as the loan is repaid, and their benefits grow tax-deferred until distribution.

Because state professional corporation (PC) laws typically restrict stock ownership to licensed professionals, medical practice ESOPs often use a parallel MSO structure. In this arrangement, the ESOP holds stock in the MSO rather than the PC itself, allowing decision-making authority over clinical matters to remain with licensed physicians while profits flow to the MSO and enhance ESOP share value.

ESOP vs. Private Equity for Medical Practice Succession

The structural similarities between private equity and ESOP transactions are significant, but the differences in long-term outcomes are equally important. Both approaches rely on similar earnings and compensation adjustments and use bank debt financing to fund the acquisition. However, private equity transactions also involve equity financing from investors, and often include rollover equity requirements and equity-based management incentive plans, while ESOPs do not require outside equity.

From a liquidity standpoint, private equity deals typically provide mostly cash at closing, along with potential earn-out arrangements. However they are taxable events and generally involve a plan to sell the practice again within five to seven years. In contrast, an ESOP can provide cash at closing, with the remainder of consideration structured as seller notes with optional warrants. ESOPs may also allow sellers to defer capital gains under Section 1042 and can eliminate federal income tax on future operating income in certain circumstances.

The two structures often reflect different ownership objectives. Private equity investors typically seek liquidity through a future transaction, while ESOPs are designed to support employee ownership over the long term.

Governance structures also differ between the two models. Private equity transactions often introduce investor oversight and strategic growth objectives, while ESOP structures preserve existing management and governance frameworks. In medical practice ESOP structures, clinical decision-making authority remains with licensed physicians in accordance with applicable state laws. ESOP transactions and private equity transactions also differ in ownership timeline and governance structure. ESOPs are generally designed around long-term employee ownership, while private equity investments typically include outside investor oversight and a defined investment horizon.

Tax Benefits of ESOPs for Medical Practices

One factor that distinguishes ESOPs from many other succession planning strategies is their potential tax advantages for medical practices and physician-owners.

For sellers organized as C corporations, Internal Revenue Code Section 1042 permits a rollover deferral of capital gains, provided the seller transfers at least 30 percent of company stock to the ESOP and reinvests in qualified replacement property within one year. The practical impact can be significant: On a $30 million sale with a $5 million basis, a taxable transaction could generate approximately $6.25 million in taxes, whereas an ESOP transaction using Section 1042 could result in no current tax liability. If the holder of the qualified replacement property dies, the property receives a step-up in basis, potentially eliminating the deferred gain permanently.

For practices organized as S corporations, a 100 percent ESOP-owned S corporation pays no federal income tax on operating income, freeing additional cash flow for debt service, growth initiatives, and reinvestment. At the participant level, annual share allocations are made in proportion to covered payroll, and benefits grow tax-deferred, subject to vesting schedules and diversification rights.

Key Considerations When Evaluating an ESOP

Like any ownership transition strategy, ESOPs present both opportunities and challenges. Potential benefits include tax savings, increased cash flow, physician-owner liquidity, capital gains deferral, the ability for sellers to remain involved, and the creation of an ownership culture that can support employee retention and engagement. Considerations may include transaction complexity, fiduciary oversight obligations, balance sheet leverage, and long-term repurchase obligation planning.

Private equity transactions often provide substantial upfront liquidity and access to capital for growth, while ESOPs may offer unique tax advantages, employee ownership benefits, and continuity of long-term ownership. The appropriate structure depends on the practice’s goals, ownership objectives, succession timeline, and growth strategy.

A formal ESOP feasibility study is the recommended first step for medical practices exploring this ownership model. The study typically includes a preliminary valuation, tax analysis, debt capacity modeling, and transaction design.

Physician-owners considering succession should clarify their goals regarding timing, control, and liquidity. They should then work with experienced ESOP counsel, transaction and valuation advisors, and trustees to evaluate whether an ESOP aligns with their succession, ownership, and long-term business objectives.

Contact one of Varnum’s Employee Stock Ownership Plan attorneys to get started and attend our upcoming webinar on Employee Stock Ownership Plans (ESOPs) For Medical Practices via Zoom on Wednesday, June 24, 11:30 a.m. – 12:30 p.m.

Nick Adamy, President at Adamy Valuation also contributed to this article.

Transferring a Disney Vacation Club Interest to the Next Generation

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Disney Vacation Club (DVC) contracts are more than vacation perks. They are deeded real property interests that require thoughtful estate planning. Whether points were purchased years ago or more recently, understanding how a DVC contract is titled, and how it will transfer at death, is critical to avoiding probate, unintended ownership outcomes, and potential family disputes.

Three Ways to Title a DVC Contract

Most DVC contracts are governed by Florida law. Generally, title may be held in three ways: individually, in a revocable trust, or through a corporate entity such as a limited liability company (LLC) or corporation. Each structure has different implications for estate administration, tax planning, creditor protection, and long-term membership management.

1. Individual Ownership

Individual ownership can take several forms, including tenancy in common, joint tenancy, joint tenancy with right of survivorship, or tenancy by the entireties. If the deed does not specify the form of ownership, and the owners are not married, Florida law defaults to tenancy in common, meaning each owner holds a separate interest that may be subject to probate.

Joint tenancy with right of survivorship allows a DVC interest to transfer automatically to the surviving owner without probate. Tenancy by the entireties, available only to married couples, provides similar survivorship benefits along with certain creditor protections under Florida law.

For out-of-state owners, the form of title may also determine whether ancillary probate proceedings in Florida are required upon the death of an owner.

2. Titling a DVC Contact in a Trust

A revocable living trust is a common planning vehicle for DVC ownership. A properly funded trust allows the grantor to retain full control during life while enabling the contract to pass to designated beneficiaries at death without probate.

Trust planning also allows families to establish customized provisions addressing maintenance fees, usage rights, and long-term governance of the membership. For example, a trust may require beneficiaries to contribute toward annual dues or risk losing usage privileges. These tailored provisions can help preserve the value of the membership and reduce the likelihood of disputes.

Families should also evaluate whether the trust should retain ownership through the contract’s expiration or distribute interests outright to beneficiaries. Ongoing trust ownership can provide centralized management but may involve continuing administration costs and tax filings.

3. Ownership Through an LLC or Corporation

In some cases, families may hold DVC contracts through an LLC or corporation. While less common, entity ownership can provide a formal structure for shared ownership, allocation of usage rights, and financial obligations through operating agreements or bylaws. Families considering entity ownership should consult legal and tax advisors regarding governance, liability exposure, and potential tax consequences.

Planning for Multiple Contracts and Multiple Heirs

Families with more than one child should consider whether purchasing several smaller contracts rather than a single large contract may allow for cleaner division of ownership. Separate contracts can be distributed individually and may be easier to sell on the secondary market if a beneficiary chooses not to retain the membership.

A key operational consideration is that contracts must carry consistent titling to be linked under a single membership number. Differently titled contracts or separate trusts may create additional membership numbers, which can complicate point management and reservation planning. Similarly, differing Use Years may complicate your vacation planning, but individual heirs may have differing preferences that may be accommodated.

Retitling an Existing DVC Contract

Owners who initially titled their contracts individually may later transfer them into a trust through an established retitling process. This process typically includes administrative fees and timing considerations, including potential restrictions related to pending reservations. Advance planning can help minimize disruptions.

Key Takeaways

Because DVC contracts are deeded real property interests, titling decisions directly affect probate exposure, transfer tax planning, creditor protection, and long-term family governance. Revocable trusts often provide flexibility and continuity, while entity ownership may be appropriate for complex shared arrangements.

Before changing title or relying on outdated estate planning documents, DVC owners should review their strategy with our experienced estate planning counselors to ensure their plan protects family interests and supports multigenerational use. Contact a member of Varnum’s Estate Planning Practice Team to discuss today.

U.S. Supreme Court Holds FAAAA Does Not Preempt Negligent-Hiring Claims Against Freight Brokers

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On May 14, 2026, the U.S. Supreme Court issued a unanimous decision in Montgomery v. Caribe Transport II, LLC, No. 24-1238, holding that negligent-hiring claims against freight brokers are not preempted by the Federal Aviation Administration Authorization Act (FAAAA). The Court concluded that such claims fall within the FAAAA’s safety exception, which preserves a state’s authority to regulate safety with respect to motor vehicles.

The decision resolves a longstanding split among federal courts and significantly expands potential liability for freight brokers and transportation brokers. Going forward, brokers may face increased exposure to state-law negligence claims arising from their carrier-selection decisions.

FAAAA Preemption and the Freight Broker Safety Exception

Freight brokers play a critical role in the U.S. supply chain, arranging freight shipments between shippers and motor carriers. Congress enacted the FAAAA in 1994 to deregulate certain economic aspects of the trucking industry and included a broad preemption provision prohibiting states from enforcing laws related to a broker’s or motor carrier’s prices, routes, or services.

Congress also included an important limitation on that preemption. The FAAAA’s safety exception provides that the statute does not restrict a state’s safety regulatory authority with respect to motor vehicles.

For years, courts disagreed on whether negligent-hiring claims against freight brokers fell within that exception. The Supreme Court’s decision in Montgomery answers that question and establishes that states may allow plaintiffs to pursue negligent-hiring claims against brokers when injuries allegedly result from the selection of an unsafe motor carrier.

Facts Behind the Supreme Court’s Freight Broker Liability Decision

Plaintiff Shawn Montgomery suffered severe injuries when a truck hauling freight struck his tractor-trailer. The shipment had been arranged by freight broker C.H. Robinson Worldwide, Inc.

Montgomery alleged that C.H. Robinson negligently selected the motor carrier despite the carrier receiving a “conditional” safety rating from the Federal Motor Carrier Safety Administration (FMCSA). According to the complaint, the carrier had documented safety deficiencies involving driver qualifications, hours-of-service compliance, vehicle maintenance, inspections, and crash history.

Montgomery argued that the broker knew or should have known that selecting the carrier created an unreasonable risk of harm to the public.

The district court dismissed the negligent-hiring claim, finding it preempted by the FAAAA, and the U.S. Court of Appeals for the Seventh Circuit affirmed. The Supreme Court reversed.

Supreme Court Rules Freight Brokers Can Be Sued for Negligent Hiring

The Supreme Court unanimously held that negligent-hiring claims against freight brokers fall within the FAAAA’s safety exception and therefore are not preempted.

The Court reasoned that state-law claims requiring brokers to exercise reasonable care when selecting motor carriers directly relate to motor vehicle safety. As a result, those claims constitute an exercise of a state’s safety regulatory authority and may proceed under state law despite the FAAAA’s general preemption provisions.

The decision answers a question that has divided federal courts for years: whether freight brokers can be held liable under state law for negligently selecting unsafe motor carriers. The Court concluded that they can.

Increased Freight Broker Liability and Litigation Risk

The Montgomery decision removes a significant defense that freight brokers have relied upon to obtain early dismissal of negligent-hiring claims.

As a result, brokers should expect an increase in trucking accident litigation naming both motor carriers and freight brokers as defendants. Plaintiffs’ attorneys may seek to expand theories of liability by challenging the adequacy of carrier-selection procedures, safety reviews, and other due diligence efforts.

The ruling may also prompt litigation over whether brokers have ongoing responsibilities to monitor carriers after initial approval and onboarding.

Carrier Selection Practices Will Receive Greater Scrutiny

Because negligent-hiring claims can now proceed under state law, a broker’s carrier-selection and onboarding practices may become central issues in future litigation.

Transportation brokers should consider reviewing and strengthening procedures related to:

  • FMCSA safety ratings and safety records
  • Carrier operating authority and regulatory compliance
  • Insurance verification
  • Crash history and out-of-service rates
  • Driver qualification information
  • Documentation of carrier-selection decisions

Maintaining thorough records of carrier evaluations, safety reviews, and onboarding decisions may become increasingly important when defending against negligent-hiring claims.

Notably, the concurrence suggested that brokers who maintain reasonable carrier-selection policies and conduct meaningful due diligence before tendering loads may be better positioned to defend against negligence allegations.

How Transportation Brokers Should Respond to the Montgomery Decision

The Supreme Court’s decision significantly changes the legal landscape for freight brokers and transportation brokers. The ruling increases potential exposure to negligent-hiring claims and underscores the importance of robust carrier-selection and risk-management practices.

Transportation brokers should evaluate their onboarding procedures, documentation protocols, carrier-vetting standards, and safety review processes to assess potential liability in light of the Court’s decision. Strengthening due diligence procedures and maintaining detailed records may help reduce risk and improve defensibility in future litigation.

For guidance regarding freight broker liability, FAAAA preemption, negligent-hiring claims, transportation broker litigation, or the impact of the Montgomery decision on your operations, contact a member of Varnum’s Litigation Practice Team.