covered claim (New York) · Go Syfert
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covered claim in New York

12 New York opinions name it 2 courts 1997–2022 1 in the last five years

The cases below were cited by New York courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
Physicians' Reciprocal Insurers v. Loebgreen
nyappdiv · 2002 · cited in 5 New York opinions naming this issue, 2006–2014
2 sentences

2014“The duty of an insurer to defend its insured arises whenever the allegations within the four corners of the underlying complaint potentially give rise to a covered claim” (Physicians’ Reciprocal Insurers v Loeb, 291 AD2d 541, 542 [2002]).

2009Co., 91 NY2d 169 [1997]). “[T]he duty of an insurer to defend its insured arises whenever the allegations within the four corners of the underlying complaint potentially give rise to a covered claim” (Physicians’ Reciprocal Insurers v Loeb, 291 AD2d 541, 542 [2002]).

55
Fitzpatrick v. American Honda Motor Co.green
ny · 1991 · cited in 6 New York opinions naming this issue, 1997–2014
2 sentences

2007It is well established that “[t]he duty of an insurer to defend its insured arises whenever the allegations within the four corners of the underlying complaint potentially give rise to a covered claim” (Physicians’ Reciprocal Insurers v Loeb, 291 AD2d 541, 542 [2002]), or whenever the insurer “has actual knowledge of facts establishing a reasonable possibility of coverage” (Fitzpatrick v American Honda Motor Co., 78 NY2d 61, 67 [1991]).

2002The duty of an insurer to defend its insured arises whenever the allegations within the four corners of the underlying complaint potentially give rise to a covered claim, or where the insurer “has actual knowledge of facts establishing a reasonable possibility of coverage” (Fitzpatrick v American Honda Motor Co., 78 NY2d 61, 65-67 ; see, Frontier Insulation Contrs. v Merchants Mut.

16
Cheektowaga Central School District v. Burlington Insurancegreen
nyappdiv · 2006 · cited in 1 New York opinions naming this issue, 2009–2009
1 sentence

2009Co., 32 AD3d 1265, 1267-1268 [2006]; 1 Ostrager and Newman, Insurance Coverage Disputes § 11.01, at 892 [14th ed] [although “ ‘other insurance’ clauses may operate to convert a primary policy into an excess policy . . ., insurance purchased as primary coverage must respond to a covered claim before policies specifically purchased as secondary coverage, regardless of the presence of ‘other insurance’ clauses in the primary policies” (citations omitted)]). .

11
Zuckerman v. City of New Yorkgreen
ny · 1980 · cited in 1 New York opinions naming this issue, 2007–2007
1 sentence

2007In opposition, Dr. Giugliano failed to raise a triable issue of fact (see Alvarez v Prospect Hosp., supra at 324; Zuckerman v City of New York, supra at 562).

11
Alvarez v. Prospect Hospitalgreen
ny · 1986 · cited in 1 New York opinions naming this issue, 2007–2007
1 sentence

2007In opposition, Dr. Giugliano failed to raise a triable issue of fact (see Alvarez v Prospect Hosp., supra at 324; Zuckerman v City of New York, supra at 562).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New York. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Federal Insurance v. Kozlowski green
nyappdiv · 2005
1 sentence

2022At this juncture, the parties' dispute is not an allocation dispute concerning the insurer's obligation to advance defense costs allocated to a covered claim, but a coverage dispute concerning whether the arbitration award is a final adjudication that triggers the fraud and contract exclusions of the policy ( see Kozlowski, 18 AD3d at 41-42 ).

12022–2022
Frontier Insulation Contractors, Inc. v. Merchants Mutual Insurance green
ny · 1997
1 sentence

2009Co., 91 NY2d 169 [1997]). “[T]he duty of an insurer to defend its insured arises whenever the allegations within the four corners of the underlying complaint potentially give rise to a covered claim” (Physicians’ Reciprocal Insurers v Loeb, 291 AD2d 541, 542 [2002]).

12009–2009
Worth Constr. v. Admiral Ins. green
ny · 2008
1 sentence

2009As the broad duty to defend “ ‘arises whenever the allegations within the four corners of the underlying complaint potentially give rise to a covered claim’ ” (Worth, 10 NY3d at 415 , quoting Frontier Insulation Contrs. v Merchants Mut.

12009–2009
Barry v. Romanosky green
nyappdiv · 1989
1 sentence

2008The allegations of negligence in the complaint implied an unintentional or unexpected event which potentially gives rise to a covered claim as against Filer (see Barry v Romanosky, 147 AD2d 605 [1989]).

12008–2008
Curtis v. Nutmeg Insurance green
nyappdiv · 1994
1 sentence

1997Co., 204 AD2d 833, 834 , lv dismissed 84 NY2d 1027 ), for even where a complaint on its face fails to state a covered claim an "insurer must provide a defense if it has knowledge of facts which potentially bring the claim within the policy’s indemnity coverage” (Fitzpatrick v American Honda Motor Co., 78 NY2d 61, 66 ).

11997–1997

Where else courts name it

TX 94 (1991–2026) CA 67 (1991–2026) NJ 35 (1989–2026) LA 29 (1980–2023) PA 27 (1944–2019) FL 27 (1980–2026) IL 22 (1978–2020) MA 15 (1994–2025) AZ 12 (1975–2021) NY 12 (1997–2022) CT 11 (1995–2014) WI 10 (1992–2022) WV 8 (1994–2023) AL 8 (1987–2010) DE 7 (1989–2022) GA 7 (1967–2021) OR 7 (1989–2023) RI 7 (1995–2006) MO 7 (1967–2021) OH 7 (1998–2025) MD 7 (1988–2019) NH 6 (1998–2013) WA 6 (1990–2004) ME 6 (2004–2019) MS 5 (1993–2011) CO 5 (1988–2016) SC 4 (2001–2024) MN 4 (1992–2025) DC 3 (1984–2003) IN 3 (2002–2002) VA 3 (1994–2009) OK 3 (1992–2004) NM 2 (1993–2017) KY 2 (1956–2006) AR 2 (1988–2003) KS 2 (1989–1994) NC 2 (1992–1994) IA 2 (1989–1993)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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