Ciasullo v. Nationwide Insurance
Opinion of the Court
Ordered that the amended order is affirmed insofar as appealed from, with costs.
A disclaimer pursuant to Insurance Law § 3420 (d) is required when the denial of coverage is based upon a policy exclusion without which the claim would be covered (see Matter of Worcester Ins. Co. v Bettenhauser; 95 NY2d 185, 188-189 [2000]; Handelsman v Sea Ins. Co., 85 NY2d 96 [1994]). In contrast, a disclaimer pursuant to Insurance Law § 3420 (d) “is unnecessary when a claim falls outside the scope of the policy’s coverage portion” (Matter of Worcester Ins. Co. v Bettenhauser, supra at 188; see Zappone v Home Ins. Co., 55 NY2d 131, 134 [1982]). The instant insurance policy was issued by the defendant Nationwide Insurance Company (hereinafter Nationwide) to the plaintiff’s father. The plaintiff, who was involved in an automobile accident, sought coverage under the supplementary uninsured motorists (hereinafter SUM) endorsement of the subject policy. Nationwide denied coverage based upon a policy exclusion to the SUM endorsement which excluded from SUM coverage “bodily injury to an insured incurred while occupying a motor vehicle owned by that insured, if such motor vehicle is not insured for SUM coverage by the policy under which a claim is made” (emphasis added). But for the exclusion, coverage would have been afforded the plaintiff under the SUM endorsement. Thus, the insurer was required to issue a timely disclaimer under Insurance Law § 3420 (d) based upon the policy exclusion (see Matter of Worcester Ins. Co. v Bettenhauser, supra; Handelsman v Sea Ins. Co., supra).
The defendants established their prima facie entitlement to
Case-law data current through December 31, 2025. Source: CourtListener bulk data.