New York State Workers' Compensation Board v. Marsh U.S.A., Inc.
The State of New York Workers’ Compensation Board appealed an order that partially granted motions to dismiss filed by several defendants, including former trustees (Zubin, Mclvor) and the Trust administrator (Marsh U.S.A., Inc.). The Trust, formed in 1998, provided workers' compensation insurance to construction employers and later operated at a deficit, leading to the plaintiff assuming its administration in 2009. Plaintiff filed claims for breach of contract and fraud against the trustees, and breach of contract and unjust enrichment against Marsh. The Supreme Court had dismissed fraud claims against Zubin and Mclvor and partially dismissed claims against Marsh based on statute of limitations and lack of agreement. On appeal, the Court affirmed the dismissal of fraud claims against Zubin and Mclvor, finding them directly related to breach of contract. However, the Court reversed the dismissal of breach of contract claims against Marsh regarding premium calculations from November 2006 to October 2007, citing the discovery of a relevant agreement. The order was therefore modified and affirmed as modified.