New York Law Review

Security Mutual Insurance Co. of New York v. Acker-Fitzsimons Corp., 31 N.Y.2d 436 (1972): Agent’s Actions and Policy Notice Requirements

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The New York Law Review

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Security Mutual Insurance Co. of New York v. Acker-Fitzsimons Corp., 31 N.Y.2d 436 (1972)

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An insurer may be estopped from enforcing strict policy notice requirements if its agent’s conduct leads the insured to reasonably believe that oral notice is sufficient, even when the policy requires written notice.

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Summary

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Acker-Fitzsimons Corp. orally notified the insurance agent (Dunn & Fowler) of an accident involving their employee, reasonably believing this was sufficient. The policy required written notice

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