Parmar v. Hermitage Insurance
Cases that cite this one
23 later published cases cite this decision.
- Liang v. Progressive Cas. Ins. Co. (Appellate Division of the Supreme Court of New York 2019)
- Barkan v. New York Schools Insurance Reciprocal (Appellate Division of the Supreme Court of New York 2009)
- American Empire Surplus Lines Ins. Co. v. ZNKO Constr., Inc. (Appellate Division of the Supreme Court of New York 2023)
- Walker v. Tighe (Appellate Division of the Supreme Court of New York 2016)
- Smith v. Guardian Life Insurance Co. of America (Appellate Division of the Supreme Court of New York 2014)
- Smith v. Guardian Life Insurance Co. of America (Appellate Division of the Supreme Court of New York 2014)
- Varshavskaya v. Metropolitan Life Insurance (Appellate Division of the Supreme Court of New York 2009)
- Alexi Home Design, Inc. v. Union Mut. Fire Ins. Co. (Appellate Division of the Supreme Court of New York 2024)
- Union Mut. Fire Ins. Co. v. CMN Props., LLC (Appellate Division of the Supreme Court of New York 2023)
- Rodriguez v. Mercury Cas. Co. (Appellate Division of the Supreme Court of New York 2022)
- Dam Props. Holding Corp. v. Union Mut. Fire Ins. Co. (Appellate Division of the Supreme Court of New York 2022)
- Friedman v. Otsego Mut. Fire Ins. Co. (Appellate Division of the Supreme Court of New York 2020)
- Indian Harbor Insurance Co. v. SP&K Construction (Appellate Division of the Supreme Court of New York 2017)
- Morales v. Castlepoint Insurance (Appellate Division of the Supreme Court of New York 2015)
- Ortiz v. Fage USA Corp. (Appellate Division of the Supreme Court of New York 2013)
- Ortiz v. Fage USA Corp. (Appellate Division of the Supreme Court of New York 2013)
- James v. Tower Insurance (Appellate Division of the Supreme Court of New York 2013)
- James v. Tower Insurance (Appellate Division of the Supreme Court of New York 2013)
- Tyras v. Mount Vernon Fire Insurance (Appellate Division of the Supreme Court of New York 2007)
- Schirmer v. Penkert (Appellate Division of the Supreme Court of New York 2007)
- Lenhard v. Genesee Patrons Co-operative Insurance (Appellate Division of the Supreme Court of New York 2006)
- Christophersen v. Allstate Insurance (Appellate Division of the Supreme Court of New York 2006)
- Curiel v. State Farm Fire & Casualty Co. (Appellate Division of the Supreme Court of New York 2006)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
Ordered that the order is modified, on the law, by deleting the provision thereof denying that branch of the defendant’s motion which was for summary judgment dismissing the claim for punitive damages and substituting therefor a provision granting that branch of the motion; as so modified, the order is affirmed, with costs.
The plaintiffs owned and managed a multi-family residence (hereinafter the Premises) for which the defendant issued a general liability policy (hereinafter the Policy), insuring the Premises as a “two family dwelling.” In September 1999 Eduardo Rivera, an infant (hereinafter the infant), allegedly sustained injuries in the basement of the Premises, where he lived with his family. The infant’s father claimed that he told the plaintiffs about the accident the following day. The plaintiffs, however, alleged that they first received notice of the accident and the potential claim against them by letter dated December 21, 1999, from the infant’s attorney. They immediately forwarded the letter to their insurance broker. The broker, in turn, asserted that in January 2000 he faxed this information to the wholesale broker, the Morstan Agency (hereinafter Morstan), an agent of the defendant. Both Morstan and the defendant deny receipt of this notice, and maintain that their first notice of any claim came by way of the summons and complaint in the underlying action served on Morstan in April 2000.
The defendant denied coverage on the grounds that the notice was untimely under the Policy provision requiring an insured to provide notice “as soon as practicable,” and that the plaintiffs
The requirement that an insured notify its liability insurance carrier of a potential claim “as soon as practicable” operates as a condition precedent to coverage (White v City of New York, 81 NY2d 955, 957 [1993]). The defendant maintains that the plaintiffs had knowledge of the potential claim weeks, if not months, before their receipt of the December 1999 letter from the infant’s attorney. In the alternative, the defendant argues that, assuming the plaintiffs did not know about the accident until December 1999, the failure to notify it of the accident until April 2000 was unreasonable as a matter of law. However, the record reveals the existence of triable issues of fact as to when the plaintiffs acquired knowledge that the infant was injured on the Premises and when the defendant was first notified of the accident. Thus, the defendant was not entitled to summary judgment based upon late notice of the accident.
The defendant also failed to demonstrate its entitlement to summary judgment based on a material misrepresentation by the plaintiffs (see Winegrad v New York Univ. Med. Ctr., 64 NY2d 851, 853 [1985]). “[T]o establish its right to rescind an insurance policy, an insurer must demonstrate that the insured made a material misrepresentation. A misrepresentation is material if the insurer would not have issued the policy had it known the facts misrepresented” (Zilkha v Mutual Life Ins. Co. of N.Y., 287 AD2d 713, 714 [2001]; cf. Gorra v New York Life Ins. Co., 276 AD2d 469, 470 [2000]; see Insurance Law § 3105 [b]). The issue of materiality is generally a question of fact for the jury (see Process Plants Corp. v Beneficial Natl. Life Ins. Co., 53 AD2d 214, 216 [1976], affd 42 NY2d 928 [1977]). To establish materiality as a matter of law, the insurer must present documentation concerning its underwriting practices, such as underwriting manuals, bulletins, or rules pertaining to similar risks, which show that it would not have issued the same policy if the correct information had been disclosed in the application (see Insurance Law § 3105 [c]; Curanovic v New York Cent. Mut. Fire Ins. Co., 307 AD2d 435, 437 [2003]; Tuminelli v First Unum Life Ins. Co., 232 AD2d 547 [1996]; Shapiro v Allstate Life Ins. Co. of N.Y., 202 AD2d 659, 660 [1994]). Conclusory statements by insurance company employees, unsupported by documentary
Assuming that the plaintiffs made the misrepresentations complained of, the conclusory statement by the defendant’s underwriter to the effect that it would not have issued the Policy had it known that the Premises included a third apartment, located in the basement, was insufficient to establish materiality as a matter of law (see Curanovic v New York Cent. Mut. Fire Ins. Co., supra; Tuminelli v First Unum Life Ins. Co., supra).
However, the claim for punitive damages should have been dismissed (see Rocanova v Equitable Life Assur. Socy. of U.S., 83 NY2d 603, 613-614 [1994]; Fulton v Allstate Ins. Co., 14 AD3d 380, 381 [2005]). Prudenti, P.J., Goldstein, Crane and Mastro, JJ., concur.
Case-law data current through September 30, 2026. Source: CourtListener bulk data.