Tozzi v. Long Island Railroad
Fred Tozzi, an employee of L & L Painting Company, Inc., was injured on the job in 1989, leading to a primary action against Long Island Railroad Company and a third-party action by the Railroad against L & L. Subsequently, L & L commenced a fourth-party action against its insurer, Commerce and Indemnity Insurance Company (C & I), seeking defense and indemnification under its commercial general liability policy. L & L moved for summary judgment, arguing the policy was ambiguous and regulatory estoppel applied, while C & I cross-moved to dismiss, citing an employee bodily injury exclusion. The court declined to apply regulatory estoppel due to the limited nature of New York's regulatory approval process for the insurance endorsement. However, the court found an ambiguity in the policy when considering the "Notice of Occurrence" endorsement alongside the exclusion. Construing this ambiguity in favor of the insured, the court granted L & L's motion for summary judgment, mandating C & I to defend and indemnify L & L, but also declared that L & L owed common-law and contractual indemnification to the Long Island Railroad Company.