Travelers Insurance v. Nory Construction Co.
Plaintiff Travelers Insurance Company initiated a subrogation action against Nory Construction Co., Inc. to recover over $3.5 million paid to satisfy a judgment against its insured, the State of New York, following a construction accident. Travelers sought common-law indemnification, arguing Nory was entirely at fault, including amounts paid beyond its policy limits. Nory countered that Travelers could not recover voluntary payments, and the claim was barred by the antisubrogation rule and untimely disclaimer. The court denied Travelers' motion for summary judgment due to insufficient evidence regarding Nory's sole fault. Ultimately, the court granted Nory's motion for summary judgment, concluding that Travelers' overpayment, made without legal compulsion or Nory's request, constituted a voluntary payment and was therefore not recoverable under equitable subrogation principles.