Never Rely on a Certificate of Insurance A Certificate Conferred No Rights Upon the Holder.

• Date: 10 January 2022

The plaintiffs relied on a certificate of insurance advising that Chipotle was an additional insured of a policy issued to a vendor. The insurer, RLI, proved that Chipotle was not named as an additional insured nor was it an additional insured by reason of a contract with the vendor. The trial court granted RLI's motion for summary judgment and the plaintiffs appealed.

In Chipotle Mexican Grill, Inc., et al. v. RLI Insurance Company; Fireman's Fund Insurance Company, Nos. 201811057, 2018-11361, 2018-14847, 201900473. Index No. 700712/16, Supreme Court of New York, Second Department (November 24, 2021) the issue of additional insured status devolved to a statement made in a certificate of insurance provided by the vendor to Chipotle.

FACTS

The plaintiffs hired the defendant Piece Management, Inc. (hereinafter PMI), to perform rodent prevention services at its restaurant located in the Roosevelt Field Mall. Afmat Wazadally was employed by PMI and was injured in the course of his work when he fell from a ladder. Wazadally commenced a personal injury action against the plaintiffs and others (hereianfter the underlying action). The plaintiffs sought to obtain insurance coverage from PMI's insurer, RLI...