Forbes v. City of New York
This case involves an appeal from an order of the Supreme Court, Bronx County, which denied National Restoration Contractors’ (NRC) motion for summary judgment seeking to dismiss a third-party complaint filed by the New York City School Construction Authority (NYCSCA). The central issue revolved around the applicability of a waiver of subrogation endorsement within a commercial general liability insurance policy, procured by NYCSCA and covering subcontractors like NRC, issued by AIU Insurance Company. The policy excluded bodily injury to employees covered by workers’ compensation, which NRC separately maintained. The appellate court affirmed the lower court’s ruling, concluding that the waiver of subrogation endorsement did not bar the third-party complaint. The court reasoned that the endorsement’s scope was limited to claims covered under the policy, and since NRC’s employee injuries were not covered by the AIU policy, the waiver was inapplicable.