Aurora Terminals Corporation v. G2g Transport, LLC

CourtNew Jersey Superior Court Appellate Division
DecidedMarch 7, 2025
DocketA-3283-23
StatusUnpublished

This text of Aurora Terminals Corporation v. G2g Transport, LLC (Aurora Terminals Corporation v. G2g Transport, LLC) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aurora Terminals Corporation v. G2g Transport, LLC, (N.J. Ct. App. 2025).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION This opinion shall not "constitute precedent or be binding upon any court ." Although it is posted on the internet, this opinion is binding only on the parties in the case and its use in other cases is limited. R. 1:36-3.

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-3283-23

AURORA TERMINALS CORPORATION,

Plaintiff-Respondent,

v.

G2G TRANSPORT, LLC, and BEACON LOGISTICS, LLC,

Defendants,

and

G2G TRANSPORT, LLC,

Defendant/Third- Party Plaintiff,

PRIME PROPERTY & CASUALTY INSURANCE INC.,

Third-Party Defendant- Appellant. ______________________________ Argued February 12, 2025 – Decided March 7, 2025

Before Judges Susswein and Bergman.

On appeal from the Superior Court of New Jersey, Law Division, Essex County, Docket No. L-7723-21.

David M. Kupfer argued the cause for appellant (Kennedys CMK LLP, attorneys; David M. Kupfer, of counsel and on the briefs; James T. Byrnes, Daniel Algieri and Dylan Greenspan, on the briefs).

Albert I. Telsey argued the cause for respondent (Meyner and Landis LLP, attorneys; Albert I. Telsey, on the brief).

PER CURIAM

This matter involves an insurance coverage dispute arising from a motor

vehicle accident that resulted in an oil spill. The central question on appeal is

whether the insurance carrier, third-party-defendant Prime Property & Casualty

Insurance, Inc. (Prime), is responsible for paying the remediation costs imposed

on its insured, defendant G2G Transport, LLC (G2G). Prime appeals a February

23, 2024 Law Division order granting summary judgment in favor of plaintiff

Aurora Terminal Corporation (Aurora) and a May 24, 2024 order denying

Prime's motion for reconsideration. The trial court's grant of summary judgment

against Prime was based on its prior summary judgment ruling in Aurora's favor

against G2G. The court had found that G2G was liable under the New Jersey

A-3283-23 2 Spill Compensation and Control Act (the Spill Act or Act), N.J.S.A. 58:10-23.11

to -23.24. The specific provision in the policy that the trial court relied on in

granting summary judgment against Prime—known as a Form MCS-90,

Endorsement for Motor Carrier Policies of Insurance for Public Liability under

Section 29 and 30 of the Motor Carrier Act of 1980 (MCS-90 endorsement)—

requires a finding that the insured was negligent, not just liable under the Spill

Act.

After reviewing the record in light of the legal principles governing

summary judgment, we conclude the trial court did not make an adequate finding

that the spill was caused by G2G's negligence. We are therefore constrained to

vacate the order and remand for the trial court to determine, applying the

summary judgment standard, whether G2G was negligent with respect to the

accident and resulting oil spill as to trigger policy coverage under the MSC -90

endorsement. In view of the remand, we need only briefly address Prime's other

contentions, which either lack merit or are rendered moot pending resolution of

the remand proceedings. We leave to the trial court's discretion whether to allow

additional discovery on the question of G2G's negligence.

A-3283-23 3 I.

We discern the following facts and procedural history from the record. In

October 2020, Prime issued a commercial automobile liability insurance policy

to G2G. The policy specifically excludes coverage for "Any Claim related to,

caused by, or arising from Hazardous Materials." This section provides:

This exclusion applies to any Hazardous Materials arising out of the actual, alleged, or threatened spilling, discharge, dispersal, seepage, migration, release or escape of Hazardous Materials, including without limitation:

a. The handling, transportation, transfer, storage, disposal, processing, treatment, or releasing or exposure to Hazardous Materials.

b. Any loss, Claim, cost, or expense arising out of any:

(1) Request, demand, or order (including consent decrees, consent orders, or administrative procedures) that any [i]nsured or others test for, monitor, clean up, remove, contain, treat, or neutralize, or in any way respond to, or assess the effects of Hazardous Materials; or

(2) Claim or Suit by or on behalf of a governmental authority seeking recovery for testing for, monitoring, cleaning up, removing, containing, treating, or neutralizing, or in any way responding to, or assessing the effects of Hazardous Materials.

Clean up costs incurred by or on behalf of any Insured for Hazardous Materials spills from any Covered Auto are not covered by this Policy.

A-3283-23 4 As required by law, 1 the policy also includes an MCS-90 endorsement,

which states,

In consideration of the premium stated in the policy to which this endorsement is attached, the insurer (the company) agrees to pay, within the limits of liability described herein, any final judgment recovered against the insured for public liability resulting from negligence in the operation, maintenance or use of motor vehicles . . . regardless of whether or not each motor vehicle is specifically described in the policy and whether or not such negligence occurs on any route or in any territory authorized to be served by the insured or elsewhere. . . . It is understood and agreed that no condition, provision, stipulation, or limitation contained in the policy, this endorsement, or any other endorsement thereon, or violation thereof, shall relieve the company from liability or from the payment of any final judgment, within the limits of liability herein described, irrespective of the financial condition, insolvency, or bankruptcy of the insured. . . . The insured agrees to reimburse the company for any payment made by the company on account of any accident, claim, or suit involving a breach of the terms of the policy, and for any payment that the company would not have been obligated to make under the provisions of the policy except for the agreement contained in this endorsement.

On March 3, 2021, G2G requested that "pollution liability" coverage be

added to the policy and that it "will be hauling [n]on [h]azardous oils." On

March 8, Prime amended the policy to include pollution coverage with an added

1 See 49 C.F.R. § 387.7. A-3283-23 5 General Change endorsement stating, "[t]he undersigned hereby represents,

acknowledges, and agrees . . . [t]o add pollution liability coverage at the current

policy limits for the [two] currently scheduled units for the remainder of the

term[.]" The endorsement further explained that "[t]his [e]ndorsement changes

the terms and conditions of the [p]olicy issued. . . . Subject to all of the terms

and conditions of the [p]olicy, unless expressly changed hereby."

On June 1, 2021, a G2G employee was operating a commercial truck in a

lot on Lister Avenue in Newark that was leased to Aurora and subleased to G2G.

The truck had a trailer-mounted metal tank, known as an intermodal, which

contained oil. As the driver maneuvered the truck out of its parking spot, an

adjacent parked truck pierced a hole in the intermodal, which immediately

started spilling oil. Nearby surveillance video captured the incident.

Prime and the New Jersey Department of Environmental Protection

(NJDEP) were notified of the spill that day. The NJDEP Bureau of Emergency

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Aurora Terminals Corporation v. G2g Transport, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aurora-terminals-corporation-v-g2g-transport-llc-njsuperctappdiv-2025.