Lightron Corporation v. Allstate Insurance Company

CourtDistrict Court, S.D. New York
DecidedJune 6, 2025
Docket1:24-cv-08452
StatusUnknown

This text of Lightron Corporation v. Allstate Insurance Company (Lightron Corporation v. Allstate Insurance Company) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lightron Corporation v. Allstate Insurance Company, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ─────────────────────────────────── LIGHTRON CORPORATION, ET AL., Plaintiffs, 24-cv-8452 (JGK)

- against - MEMORANDUM OPINION AND ORDER ALLSTATE INSURANCE COMPANY, Defendant. ─────────────────────────────────── JOHN G. KOELTL, District Judge: The plaintiffs, Lightron Corporation and ISC Properties Inc, brought this action against the defendant, Allstate Insurance Company (“Allstate”) as corporate successor to Northbrook Indemnity Company (“Northbrook”), seeking to enforce remediation rights for contamination arising from a Superfund site, under an insurance policy issued by Northbrook. Allstate seeks to implead several third-party defendants. The plaintiffs oppose Allstate’s motion to file a third-party complaint. For the following reasons, the motion for leave to file a third- party complaint is granted. I. The plaintiffs allege that they have been named by the United States Environmental Protection Agency (the “EPA”) as potentially responsible parties for remediation of a contaminated Superfund Site (the “Site”). See Compl. ¶ 2, ECF No. 1. Between 1955 and 1979, the plaintiffs allegedly engaged in metal plating, polishing, and lacquering operations at the Site. See id. ¶ 10. The plaintiffs allege that their liability for contamination at the Site arose, in large part, out of an accident that occurred in 1979 while the plaintiffs were covered

by the Northbrook Policy. See id. ¶ 12. Specifically, the plaintiffs allege that in February 1979, a fire main burst, releasing a large amount of pressurized water that washed contaminated soil into Furnace Brook—a nearby body of water. See id. ¶¶. 9-25. The plaintiffs now seek insurance coverage from Allstate— Northbrook’s corporate successor. The Northbrook policy covers accidents which result in personal injury and property damage, provided that such personal injury or property damage does not arise “out of the discharge, dispersal, release or escape of smoke, vapors, soot, fumes, acids, alkalis, toxic chemicals, liquids or gases, waste materials or other irritants,

contaminants or pollutants into . . . any water course or body of water.” Id. ¶¶ 5-6.1 The parties agree that this carveout applies to any gradual pollution of Furnace Brook. However, the policy also contains a “carve-in” for discharges that are “sudden and accidental”—like burst pipes. See id. ¶ 7.

1 Unless otherwise noted, this Memorandum Opinion and Order omits all internal alterations, citations, footnotes, and quotation marks in quoted text. On November 6, 2024, the plaintiffs sued Allstate, seeking to require Allstate to pay the cost of remediation under the Northbrook Policy. ECF No. 1. On February 19, 2025, Allstate

sought permission to file a third-party complaint. ECF No. 24. In its proposed third-party complaint, Allstate seeks to implead several insurance companies, alleging that they insured the plaintiffs between 1967 and 1973 and may be liable for some of the remediation costs. See ECF No. 25, Ex. 2 (“3d Party Compl.”), at ¶ 5. In a declaration accompanying the motion for leave to file a third-party complaint, Allstate asserts that the plaintiffs entered into a “Consent Order” with the EPA that required the plaintiffs to investigate and remediate pollution at the Site occurring between 1955 and 1979. See ECF No. 35, Ex. 2 (“Consent Order”). Because pollution prior to the alleged 1979 accident is also covered by the plaintiffs’ Consent Order with

the EPA, Allstate alleges that the proposed third-party defendants may be liable for remediation costs associated with the Superfund Site. Allstate characterizes its claim against the third-party defendants as one for contribution and subrogation. See 3d Party Compl. ¶ 6. II. Rule 14(a) of the Federal Rules of Civil Procedure provides that “[a] defending party may, as third-party plaintiff, serve a summons and complaint on a nonparty who is or may be liable to it for all or part of the claim against it. But the third-party plaintiff must, by motion, obtain the court’s leave if it files the third-party complaint more than 14 days after serving its

original answer.” Fed. R. Civ. P. 14(a)(1). Whether to permit the defendant to implead a third party rests in the trial court’s discretion. See Kenneth Leventhal & Co. v. Joyner Wholesale Co., 736 F.2d 29, 31 (2d Cir. 1984). “The purpose of this rule is to promote judicial efficiency by eliminating the necessity for the defendant to bring a separate action against a third individual who may be secondarily or derivatively liable to the defendant for all or part of the plaintiff’s original claim.” McLaughlin v. Biasucci, 688 F. Supp. 965, 967 (S.D.N.Y. 1988). “Timely motions for leave to implead non-parties should be freely granted to promote this efficiency.” Shafarman v. Ryder Truck Rental, Inc., 100 F.R.D. 454, 459 (S.D.N.Y. 1984).

Courts consider the following factors in determining whether to grant leave: “(i) whether the movant deliberately delayed or was derelict in filing the motion; (ii) whether impleading would unduly delay or complicate the trial; (iii) whether impleading would prejudice the third-party defendant; and (iv) whether the third-party complaint states a claim upon which relief can be granted.” Too, Inc. v. Kohl’s Dep’t Stores, Inc., 213 F.R.D. 138, 140 (S.D.N.Y. 2003). III. In this case, the motion for leave to file a third-party complaint was timely and the plaintiffs oppose Allstate’s motion

on the grounds that: (1) the third-party complaint fails to state a claim upon which relief can be granted; (2) it would unduly delay the case and complicate the trial, and (3) it would prejudice both the plaintiffs and the proposed third parties. A. Allstate Has Stated a Claim The plaintiffs first contend that Allstate’s proposed third-party complaint fails to state a claim. To determine whether a third-party complaint states a claim upon which relief can be granted, courts apply the Rule 12(b)(6) standard. See Melito v. Am. Eagle Outfitters, Inc., No. 14-cv-2440, 2016 WL 6584482, at *2 (S.D.N.Y. Nov. 7, 2016). In deciding a Rule 12(b)(6) motion to dismiss for failure

to state a claim, the Court must accept the allegations in the complaint as true and draw all reasonable inferences in the plaintiff’s favor. McCarthy v. Dun & Bradstreet Corp., 482 F.3d 184, 191 (2d Cir. 2007). To survive a motion to dismiss, the plaintiff’s complaint must contain “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). While the Court should construe the factual allegations in the light most favorable to the

plaintiff, “the tenet that a court must accept as true all of the allegations contained in a complaint is inapplicable to legal conclusions.” Id. In this case, Allstate has plausibly stated a claim for contribution against the proposed third-party defendants. See 3d Party Compl. ¶ 24. The Complaint acknowledges that the pollution accumulated between 1955-1979.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McCarthy v. Dun & Bradstreet Corp.
482 F.3d 184 (Second Circuit, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
McLaughlin v. Biasucci
688 F. Supp. 965 (S.D. New York, 1988)
Falcone v. MarineMax, Inc.
659 F. Supp. 2d 394 (E.D. New York, 2009)
Too, Inc. v. Kohl's Department Stores, Inc.
213 F.R.D. 138 (S.D. New York, 2003)
Shafarman v. Ryder Truck Rental, Inc.
100 F.R.D. 454 (S.D. New York, 1984)

Cite This Page — Counsel Stack

Bluebook (online)
Lightron Corporation v. Allstate Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lightron-corporation-v-allstate-insurance-company-nysd-2025.