Did opening car door cause an “auto accident”?
James Henderson and Michelle Williams Henderson filed a lawsuit asking a New York court to declare that their automobile insurer, New York Central Mutual Fire Insurance Company, was required to defend and indemnify them in an action filed by Anthony Prave III. Prave’s lawsuit alleged that James Henderson negligently struck him while opening the driver’s door of the vehicle covered by the New York Central Mutual policy. The policy provided coverage for damages “for which any ‘insured’ becomes legally responsible because of an automobile accident.” The Hendersons argued that the language of the policy applied to the facts of the case. The lower court disagreed and found in favor of the insurer; the Hendersons appealed. On appeal, the Supreme Court, Appellate Division, Fourth Depart-ment, New York, first analyzed the insurer’s duty to defend. The court noted that the duty to defend is “exceedingly broad” and that an insurer must provide a defense “whenever the allegations of the complaint
