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Pittsburgh v. Hartford Insurance Company of the Midwest

Citations: 717 N.E.2d 1077; 93 N.Y.2d 983; 695 N.Y.S.2d 740; 1999 N.Y. LEXIS 1426

Court: New York Court of Appeals; July 6, 1999; New York; State Supreme Court

Narrative Opinion Summary

The Court of Appeals of the State of New York affirmed the Appellate Division's order, concluding that the certified question was unnecessary to address since the Appellate Division's order reversing the trial court's judgment was final. The central issue in the prior lawsuit involving Chaos Construction Corporation and National Union Fire Insurance Company was whether National had a duty to defend and indemnify Chaos in a wrongful death action. This issue differs from the current case, where National is seeking a declaration that Hartford Insurance Company is responsible for contribution as a coinsurer of Chaos. The court noted that there was a lack of "identicality of an issue," which precluded Hartford from establishing collateral estoppel against National. Consequently, the Supreme Court's resolution of the previous case does not bar National from pursuing its contribution claim now. The order was affirmed, with costs awarded.

Legal Issues Addressed

Collateral Estoppel and Identicality of Issues

Application: The court determined that the lack of identical issues between the previous and current cases precluded the application of collateral estoppel.

Reasoning: The court noted that there was a lack of 'identicality of an issue,' which precluded Hartford from establishing collateral estoppel against National.

Contribution Among Coinsurers

Application: National Union Fire Insurance Company's current claim seeks a declaration that Hartford Insurance Company is liable for contribution as a coinsurer.

Reasoning: This issue differs from the current case, where National is seeking a declaration that Hartford Insurance Company is responsible for contribution as a coinsurer of Chaos.

Duty to Defend and Indemnify in Insurance Disputes

Application: The case distinguished between the duty to defend and indemnify in a wrongful death action and the current claim for contribution among insurers.

Reasoning: The central issue in the prior lawsuit involving Chaos Construction Corporation and National Union Fire Insurance Company was whether National had a duty to defend and indemnify Chaos in a wrongful death action.

Finality of Appellate Division Orders

Application: The Appellate Division's order was considered final, making the certified question unnecessary to address.

Reasoning: The Court of Appeals of the State of New York affirmed the Appellate Division's order, concluding that the certified question was unnecessary to address since the Appellate Division's order reversing the trial court's judgment was final.