Yoda, LLC v. National Union Fire Insurance
Opinion of the Court
The National Union excess policy follows the form of a commercial general liability policy, issued by First Specialty to Queens Stainless, that provides coverage to its insured for damages arising from bodily injury, and excludes coverage for liability arising from a contractual “agreement,” except if the insured has assumed liability for such damages under an “insured contract,” such as the subcontract between Yoda and Queens Stainless. The First Specialty policy also provides that its employer’s liability exclusion “does not apply to liability assumed by the insured under an ‘insured contract,’ ” and requires the insurer to defend an indemnitee of the insured in certain circumstances.
In 2003, Yoda tendered the defense and indemnity in the underlying action to Queens Stainless and its insurers, and First Specialty accepted the tender, although no action for indemnification had been commenced against Queens Stainless. National Union actively participated in and monitored the litigation for the next three years, without issuing any disclaimer. In 2006, it accepted First Specialty’s tender of its policy in connection with a court-ordered mediation, and attended the mediation with authority to settle the underlying action. Only after partial summary judgment was awarded in favor of the plaintiffs in the underlying action, and the damages trial was scheduled to begin, did National Union disclaim coverage, asserting that it had just “discovered” that the certificate of insurance provided to it by Yoda, which names Yoda and Riverhead as additional insureds, was false.
National Union’s failure to timely disclaim coverage after tender was made by a party claiming indemnification from its insured, as required by Insurance Law § 3420 (d), precludes it from disclaiming based on the employer’s liability exclusion. However, the failure to disclaim “does not create coverage which
Although Insurance Law § 3420 (d) does not create coverage, an insurance company may be estopped “from denying or disclaiming coverage where the proper defending party relied to its detriment on that coverage and was prejudiced by the delay of the insurance company in denying or disclaiming coverage based on the loss of the right to control its own defense” (Liberty Ins. Underwriters, Inc. v Arch Ins. Co., 61 AD3d 482, 482 [2009] [internal quotation marks and citation omitted]; Federated Dept. Stores, Inc. v Twin City Fire Ins. Co., 28 AD3d 32, 38 [2006]). The doctrine may be applied in disputes between insurers (see Liberty Ins. Underwriters, 61 AD3d at 482). However, “[prejudice is established only where the insurer’s control of the defense is such that the character and strategy of the lawsuit can no longer be altered” (Federated Dept. Stores, 28 AD3d at 39).
In support of their motion for summary judgment, plaintiffs submitted evidence that National Union acknowledged coverage in correspondence and actively participated in the defense, culminating in its lead role in the mediation, and that plaintiffs had been prejudiced in the defense of the underlying action. If National Union had disputed coverage in a reasonably timely manner, plaintiffs could have impleaded Queens Stainless, thereby triggering insured contract coverage or, at least, timely resolution of any disclaimer. Plaintiff United National asserts that it relied on National Union’s conduct and allowed its file to become inactive, believing that the matter would settle within the limits of the insurance provided by Queens Stainless’s insurers. In opposition, National Union claimed that it had been misled by Yoda’s tender of a certificate of insurance showing coverage. However, there is no evidence that Yoda acted in bad faith, and nothing prevented National Union from obtaining a copy of
Case-law data current through December 31, 2025. Source: CourtListener bulk data.