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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. CA 14-01911
Regular Panel Decision
Jun 12, 2015

REGENCY OAKS CORPORATION v. NORMAN-SPENCER MCKERNAN, INC.

Regency Oaks Corporation, a professional employer organization, filed a fraud action against Norman-Spencer McKernan, Inc., an insurance agency. The plaintiff alleged that an employee of the defendant provided a falsified workers’ compensation insurance policy and a certificate of liability insurance, directing premium payments to his private company, PIM, under the false pretense that PIM was a division of the defendant. After receiving a penalty from the New York State Workers’ Compensation Board, plaintiff received a forged letter confirming coverage. The defendant's employee was later terminated for embezzlement from another client. The Supreme Court granted plaintiff partial summary judgment on liability, which was affirmed by the Appellate Division, Fourth Judicial Department, concluding that plaintiff reasonably relied on the employee's apparent authority.

FraudApparent AuthorityWorkers' Compensation InsuranceEmployee MisconductSummary JudgmentInsurance Agency LiabilityProfessional Employer OrganizationFalsified DocumentsAgency LawAppellate Review
References
11
Case No. MISSING
Regular Panel Decision

Regency Oaks Corp. v. Norman-Spencer McKernan, Inc.

The dissenting opinion argues that the Supreme Court erred in granting the plaintiff's motion for partial summary judgment. The case involves a plaintiff seeking workers' compensation insurance who dealt with an employee of the defendant. Despite the plaintiff having contact with the defendant's principal regarding the insurance, the dissent contends there is a triable issue of fact regarding the reasonableness of the plaintiff's reliance on the employee's apparent authority. Evidence showed the employee used personal contact information and documents from "Professional Insurance Managers" (PIM), a separate entity, and the policy itself listed PIM, not the defendant. Furthermore, premium payments were directed to an account controlled by PIM, and the plaintiff received a forged letter after being notified by the New York State Workers’ Compensation Board that the policy was not in effect.

Workers' Compensation InsuranceApparent AuthoritySummary JudgmentReasonable InquiryAgent MisconductInsurance ProducerForged DocumentsAppellate DissentNew York LawEmployer Liability
References
3
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