Reidy Contracting Group, LLC v. Mt. Hawley Insurance Company

CourtCourt of Appeals for the Second Circuit
DecidedFebruary 12, 2026
Docket24-1069
StatusPublished

This text of Reidy Contracting Group, LLC v. Mt. Hawley Insurance Company (Reidy Contracting Group, LLC v. Mt. Hawley Insurance Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reidy Contracting Group, LLC v. Mt. Hawley Insurance Company, (2d Cir. 2026).

Opinion

24-1069 Reidy Contracting Group, LLC v. Mt. Hawley Insurance Company

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

August Term 2024

(Argued: February 21, 2025 Decided: February 12, 2026)

No. 24-1069

––––––––––––––––––––––––––––––––––––

REIDY CONTRACTING GROUP, LLC; MERCHANTS MUTUAL INSURANCE COMPANY,

Plaintiffs-Appellees,

-v.-

MT. HAWLEY INSURANCE COMPANY,

Defendant-Appellant.

Before: LIVINGSTON, Chief Judge, MENASHI, and MERRIAM, Circuit Judges.

Defendant-Appellant Mt. Hawley Insurance Company appeals a final judgment entered on March 29, 2024, by the United States District Court for the Western District of New York (Crawford, J.), denying its motion for summary judgment and granting Plaintiffs-Appellees Reidy Contracting Group, LLC and Merchants Mutual Insurance Company summary judgment. On appeal, Mt. Hawley argues that the district court erred in holding that Reidy was an additional insured and that the Employers Liability Exclusion did not bar coverage. We disagree. We hold that Reidy is an additional insured and that, because the Exclusion is ambiguous, we must construe it against the drafter, Mt. Hawley, in

1 accordance with contra proferentem. We therefore AFFIRM the judgment of the district court.

JUDGE MENASHI dissents in a separate opinion.

FOR PLAINTIFFS-APPELLEES: RICHARD A. GALBO (Ashlyn M. Capote, on the brief), Goldberg Segalla LLP, Buffalo, NY.

FOR DEFENDANT-APPELLANT: TIMOTHY E. DELAHUNT, Delahunt Law PLLC, Buffalo, NY.

DEBRA ANN LIVINGSTON, Chief Judge:

A ceiling collapsed at a construction site, injuring three workers. This

insurance dispute ensued. The question presented is whether Mt. Hawley

Insurance Company (“Mt. Hawley”), which issued an excess liability policy to

Vanquish Contracting Corporation (“Vanquish”), the subcontractor, is required to

provide additional insurance coverage to the general contractor on the site, Reidy

Contracting Group, LLC (“Reidy”). The United States District Court for the

Western District of New York (Crawford, J.) said yes, and granted summary

judgment to Reidy and its commercial general liability insurer, Merchants Mutual

Insurance Company (“Merchants”). Mt. Hawley now appeals, contending that

Reidy is not an additional insured under its policy and that its Employers Liability

Exclusion bars coverage. We disagree, and affirm the judgment of the district

court.

2 BACKGROUND

I. Factual Background 1

Reidy was the general contractor for a demolition project at 160 Lexington

Avenue, New York. In 2012, Reidy hired Vanquish as a subcontractor. As a

condition of this arrangement, Reidy required Vanquish to procure insurance that

would protect Reidy as an additional insured from claims arising, inter alia, “out

of or in any way connected with the operations performed hereunder by or on

behalf of [Vanquish] . . . without regard to the negligence of any of them or

any . . . other subcontractor.” A-313. 2

Consistent with this agreement, Vanquish entered into an excess liability

contract with Mt. Hawley in which Vanquish is the named insured and the word

“insured” is otherwise defined as “any person or organization qualifying as an

insured under the terms of the underlying insurance.” 3 A-754. This policy is in

excess to Vanquish’s commercial general liability coverage with Endurance

1 The factual background presented here is based on undisputed facts from the parties’ submissions at summary judgment. 2 Citations to the Appendix are indicated using the prefix “A.” 3 The named insured is the party who purchases the insurance at hand. Under “ordinary interpretation of an ordinary business contract,” the additional insured party is anyone other than the named insured who is protected by the policy. Kerrigan v. RM Assocs., Inc., 892 N.Y.S.2d 350, 351–52 (App. Div. 2009).

3 American Specialty Insurance Company (“Endurance”).

a. The Insurance Policy

The Mt. Hawley policy provides that “except where provisions to the

contrary appear herein,” it “is subject to all of the conditions, agreements,

exclusions, and limitations of and shall follow the underlying insurance in all

respects.” A-754. We therefore treat the underlying insurance policy—the

Endurance policy—as being subsumed in the Mt. Hawley policy. Three

provisions are particularly relevant to this appeal: 1) the “Coverage Grant” in the

Endurance policy, which sets out the policy’s general scope of protection; 2) the

“Employers Liability Exclusion” in the Mt. Hawley policy, which details

conditions under which covered entities will be denied coverage; and 3) the

“Separation of Insureds Clause” in the Mt. Hawley policy, which explains how to

interpret the policy.

1. Coverage Grant

The Mt. Hawley policy defines an insured as “any person or organization

qualifying as an insured person under the terms of the underlying insurance.”

A-754. The underlying Endurance policy, in turn, provides that “[t]he following

are included as additional insureds”:

4 Any entity required by written contract . . . to be named as an insured is an insured but only with respect to liability arising out of [Vanquish’s] premises, "[Vanquish’s] work" for the additional insured, or acts or omissions of the additional insured, in connection with their general supervision of "[Vanquish’s] work" to the extent set forth below.

A-833. 4

2. Employers Liability Exclusion

In the Mt. Hawley policy, the Employers Liability Exclusion establishes that

4 The Limitations Clause in the Endurance policy provides further that the insurance does not apply to:

a) "Bodily injury" or " property damage" occurring after:

1) All work on the project (other than service maintenance or repairs) to be performed by or on behalf of the additional insured(s) at the site of the covered operations has been completed; or

2) That portion of "[Vanquish’s] work" out of which the injury or damage arises has been put to its intended use by any person or organization other than another contractor or subcontractor engaged in performing operations for a principal as a part of the same project.

b) "Bodily injury" or "property damage" arising out of any act, omission or negligence of the additional insured(s) or any of their "employees" or "temporary workers", other than the general supervision of work performed for the additional insured(s) by [Vanquish].

A-833–34.

5 the policy will not cover bodily injuries suffered by:

1. An "employee" of any insured arising out of and in the course of:

a. Employment by the insured, or

b. Performing duties related to the conduct of the insured’s business; or

2. The spouse, child, parent, brother or sister of that "employee" as a consequence of paragraph 1. above.

A-771.

3. Separation of Insureds Clause

The Separation of Insureds Clause instructs that “[e]xcept with respect to

the limits of liability,” the Mt. Hawley policy “applies as if each Named Insured

were the only Named Insured and separately to each insured against whom claim

is made or suit is brought.” A-760.

b. The Accident and Coverage

On January 8, 2013, Vanquish’s employees were performing hand

demolition on the interior walls of 160 Lexington Avenue. No employees from

other companies were working that day. Suddenly, a portion of a decorative

plaster ceiling collapsed, taking down a scaffold and three Vanquish employees.

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Reidy Contracting Group, LLC v. Mt. Hawley Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reidy-contracting-group-llc-v-mt-hawley-insurance-company-ca2-2026.