Tempesta v. City of New York
A plaintiff was injured after falling from a ladder while working for Confort & Company at premises owned by the New York City Industrial Development Agency. The plaintiff sued the Agency under Labor Law. The Agency initiated a third-party action against Confort for common-law contribution and indemnification. Confort, which had general liability insurance naming both itself and the Agency as insureds, moved for summary judgment to dismiss the third-party complaint, arguing the insurance waived the Agency's rights up to the policy limit. The Agency cross-moved to amend its complaint to assert contractual indemnification. The Supreme Court granted Confort's motion and denied the Agency's cross-motion. The appellate court affirmed, holding that the Aetna policy covered Confort's indemnification liability, and an insurer cannot seek subrogation against its own insured for a covered risk.