Privilege Underwriters Reciprocal Exch. v. SBP N.Y., LLC

2024 NY Slip Op 32217(U)
CourtNew York Supreme Court, New York County
DecidedJuly 1, 2024
StatusUnpublished
Cited by1 cases

This text of 2024 NY Slip Op 32217(U) (Privilege Underwriters Reciprocal Exch. v. SBP N.Y., LLC) is published on Counsel Stack Legal Research, covering New York Supreme Court, New York County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Privilege Underwriters Reciprocal Exch. v. SBP N.Y., LLC, 2024 NY Slip Op 32217(U) (N.Y. Super. Ct. 2024).

Opinion

Privilege Underwriters Reciprocal Exch. v SBP N.Y., LLC 2024 NY Slip Op 32217(U) July 1, 2024 Supreme Court, New York County Docket Number: Index No. 152866/2021 Judge: David B. Cohen Cases posted with a "30000" identifier, i.e., 2013 NY Slip Op 30001(U), are republished from various New York State and local government sources, including the New York State Unified Court System's eCourts Service. This opinion is uncorrected and not selected for official publication. INDEX NO. 155984/2020 NYSCEF DOC. NO. 67 RECEIVED NYSCEF: 07/01/2024

SUPREME COURT OF THE STATE OF NEW YORK NEW YORK COUNTY PRESENT: HON. DAVID B. COHEN PART 58 Justice ---------------------------------------------------------------------------------X INDEX NO. 152866/2021 PRIVILEGE UNDERWRITERS RECIPROCAL EXCHANGE MOTION DATE as subrogee of THOMAS PETERFFY and 432 PARK AVENUE #84A LTD., MOTION SEQ. NO. 002 Plaintiff,

-v- SBP NEW YORK, LLC, PEMBROOKE & IVES INC., STH PAINTING, INC., REN INTERIORS, LLC, FRESCO DECISION + ORDER ON DECORATIVE PAINTING, INC., RAEL AUTOMATIC MOTION SPRINKLER CO., INC., LEWIS A. SANDERS and ALICE SANDERS,

Defendants. ---------------------------------------------------------------------------------X AND THIRD-PARTY ACTIONS.

The following e-filed documents, listed by NYSCEF document number (Motion 002) 74,75,76,77,78,79,80,81,82,83,84,85,86,87,88,89,90,91,92,93,94,95,96,103,104,105,106,107,108,109, 110,111,112,113,114,115,116,117. were read on this motion to/for DISMISS .

In this subrogation action, defendants Lewis A. Sanders and Alice Sanders (collectively,

Sanders) move pursuant to CPLR 3211(a)(1) and (a)(7) for an order dismissing plaintiff’s

complaint and the cross-claims asserted against them by defendants Pembrooke & Ives Inc., STH

Painting, Inc., Ren Interiors, LLC, Fresco Decorative Paintings, Inc., and Rael Automatic

Sprinkler CO., Inc. (collectively, Cross-Claimants).

I. PERTINENT BACKGROUND

Subrogors Thomas Peterffy and 432 Park Avenue #84A LTD (collectively, Peterffy) and

defendants Sanders owned separate residential units in a mixed-use luxury condominium

building located at 432 Park Avenue in Manhattan. The complaint alleges that on April 1, 2018,

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a fire broke out in Sanders’ apartment unit, which was undergoing renovations, and allegedly

caused damage to personal property owned by Peterffy in the amount of $643,000.

As a result, Peterffy submitted a claim to plaintiff, his insurance provider, in accordance

with his insurance policy, and plaintiff reimbursed Peterffy $393,000 after applying a $250,000

policy deductible.

In the instant action, plaintiff asserts causes of action for negligence and breach of

contract against defendants, and Cross-Claimants assert claims for common-law indemnification

and contribution against Sanders. Fresco and STH have also assert cross-claims for contractual

indemnification against Sanders.

II. DISCUSSION

Sanders argues that plaintiff’s claims against them are precluded pursuant to the

governing bylaws of their condominium, by which Peterffy waived the right to sue in

subrogation, and that the cross-claims are improper because Sanders never exercised supervisory

control over the renovation project. Plaintiffs contend that the waiver of subrogation rights in the

bylaws do not bar distinct claims for breach of an alteration agreement that supplemented the

bylaws, and Cross-Claimants maintain that Sanders’s motion is premature and that there is no

legal basis for dismissal.

On a motion pursuant to CPLR 3211(a)(1), “a dismissal is warranted only if the

documentary evidence submitted conclusively establishes a defense to the asserted claims as a

matter of law” (Leon v Martinez, 84 NY2d 83, 88 [1994]). Dismissal of a complaint pursuant to

CPLR 3211(a)(7) requires that the pleading “be afforded a liberal construction” (see id.; CPLR

3026), and “[The court must] accept the facts as alleged in the complaint as true, accord plaintiffs

the benefit of every possible favorable inference, and determine only whether the facts as alleged

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fit within any cognizable legal theory” (Leon, 84 NY2d at 87-88 [1994]; see 511 W. 232nd

Owners Corp. v Jennifer Realty Co., 98 NY2d 144 [2002]).

“Condominium governance . . . is guided by the bylaws adopted by the association . . .

[and] are in essence, an agreement among all of the individual unit owners as to the manner in

which the condominium will operate, and which set forth the respective rights and obligations of

unit owners, both with respect to their own units and the condominium’s common elements”

(Board of Mgrs. of the 28 Cliff St. Condominium v Maguire, 191 AD3d 25, 29 [1st Dept 2020]

[internal quotation marks and citation omitted]).

Here, the parties’ condominium was governed by three sets of bylaws: the Residential

ones governing the use and occupancy of residential units, the Commercial ones governing the

use and occupancy of commercial units, and the Condominium ones governing the use and

occupancy of the entire condominium (NYSCEF Doc. No. 76 at ¶30-31; Doc. No. 105 at ¶5).

Section 6.4.2 of the Residential bylaws, entitled “Insurance,” states,

All policies obtained by any Residential Unit Owner, or by the Residential Board on behalf of the Residential Section or the Residential Unit Owners, shall provide that the liability of the carriers issuing insurance obtained by the Condominium Board shall not be affected or diminished by reason of any additional insurance carried by the Residential Board or any other Unit Owner and shall contain a waiver of the insurer's right of subrogation against the Condominium Board, the Residential Board and any Unit Owner.

(Doc. No. 89).

Pursuant to the clear terms of the Residential bylaws, all insurance policies obtained by

residential unit owners were required to contain a subrogation waiver, and therefore plaintiff and

its subrogors waived the right to sue Sanders to recover any insurance proceeds paid by plaintiff

(see Aspen Ins. Co. v Newman, 202 AD3d 613 [1st Dept 2022] [insurer’s lawsuit for insurance

payments made to condominium to reimburse it for property damage allegedly caused by fire in

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defendants’ condominium unit was barred as bylaws required policy containing waiver of

subrogation rights]; Allstate Indem. Co. v Virfra Holdings, LLC, 124 AD3d 528, 528 [1st Dept

2015] [valid subrogation waiver precludes action to recover insurance payments]).

Plaintiff’s argument that the Condominium bylaws required a waiver of subrogation only

in certain insurance policies is unavailing, as the applicable bylaws here are the Residential ones,

given that the fire occurred in a residential unit and damage was allegedly caused to another

residential unit, and those bylaws require a subrogation waiver in all insurance policies. Sanders

thus demonstrates that the documentary evidence here, the bylaws, conclusively establish a

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Related

American Home Assur. Co. v. SBP N.Y., LLC
2024 NY Slip Op 34466(U) (New York Supreme Court, New York County, 2024)

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Bluebook (online)
2024 NY Slip Op 32217(U), Counsel Stack Legal Research, https://law.counselstack.com/opinion/privilege-underwriters-reciprocal-exch-v-sbp-ny-llc-nysupctnewyork-2024.