Michael J. Carlson, Sr. v. American International Group, Inc.
A jury awarded Michael Carlson $20 million following his wife's death in an accident involving an MVP truck driven by William Porter. The Appellate Division later reduced the judgment and dismissed claims against DHL. Carlson then sued DHL's insurers, National Union and AAIC, under Insurance Law § 3420, arguing the MVP vehicle qualified as a "hired auto" and that the policies were "issued or delivered" in New York. While the Supreme Court initially allowed the claims, the Appellate Division reversed both, finding no "hired auto" coverage and that the policies were not "issued or delivered" in New York. The Court of Appeals reinstated Carlson's claims against the insurers, holding that the "hired auto" issue presented a question of fact and that "issued or delivered" in Insurance Law § 3420 applies to policies covering insureds and risks within New York. The court, however, affirmed the dismissal of Carlson's other claims for fraud, bad faith, General Business Law violations, and conspiracy.