310 East 74 LLC v. Fireman's Fund Insurance
The Supreme Court affirmed an order granting the defendant insurer's motion for summary judgment, thereby relieving the insurer of the duty to defend or indemnify plaintiffs in an underlying personal injury action. The court determined that plaintiffs' seven-month delay in notifying the insurer of the accident was unreasonable and that they failed to establish a good-faith belief in nonliability. Key evidence included the building superintendent's knowledge of the worker's fall and apparent injury, which was imputed to the plaintiffs and necessitated a more thorough inquiry. Additionally, the accident involved a construction worker on plaintiffs' property, indicating potential Labor Law liability, and the appearance of an investigator further put plaintiffs on notice. Finally, the court noted that the insurer was not obligated to demonstrate prejudice from the untimely notice, as the policy predated the relevant amendments to Insurance Law § 3420 (a) (5).