Key Takeaway
New York court clarifies insurance companies don't need exhaustive documentation when proving no coverage exists, setting practical standards for no-fault cases.
Understanding Insurance Coverage Documentation Requirements
When insurance companies assert that no policy was in effect at the time of an accident, questions often arise about how thoroughly they must document their search efforts. This issue frequently surfaces in New York No-Fault Insurance Law cases, where proving the existence or absence of coverage is crucial for determining liability and benefits.
The courts have established practical guidelines for what constitutes adequate proof when an insurer claims no coverage existed. Rather than requiring exhaustive documentation of every search step, the law recognizes a middle ground that balances thoroughness with practicality. This standard helps streamline litigation while ensuring legitimate coverage disputes receive proper attention.
Jason Tenenbaum’s Analysis:
Delta Diagnostic Radiology, P.C. v American Tr. Ins. Co., 2014 NY Slip Op 51240(U)(App. Term 2d Dept. 2014)
“Despite plaintiff’s contention to the contrary, defendant was not required to describe in detail the steps which it had taken in searching its records in order to demonstrate that there was no coverage in effect at the time of the accident”
This is a good case because the briefs that i get from certain firms state that an exhaustive search is necessary to determine that there is no policy of insurance in effect. While a conclusory “I looked and saw nothing might not be sufficient”, there is no need to go into the intricate detail of underwriting. A happy medium – 2 paragraphs – should do the trick.
Key Takeaway
Courts reject both extremes in coverage documentation cases. While insurance companies cannot simply state they found no coverage without explanation, they also don’t need to provide exhaustive details of their search methodology. A reasonable middle approach with adequate documentation typically satisfies legal requirements.
Related Articles
- Triable issue of fact as to lack of coverage
- Understanding collateral estoppel in New York no-fault insurance coverage disputes
- When appellate courts grant summary judgment for non-insured events
- Business record entries and motor vehicle accident coverage
- New York No-Fault Insurance Law
Legal Update (February 2026): Since this 2014 post, New York’s insurance regulations and documentation standards for coverage determinations may have been modified through Insurance Department bulletins, regulatory amendments, or subsequent appellate decisions. Practitioners should verify current requirements for proving absence of coverage and any updated procedural standards that may affect how insurers must document their search efforts in no-fault cases.
