Duty to Defend Granted Unless Exclusions Solely and Entirely Apply; Indemnity Deferred Where Exclusions Turn on Unresolved Facts

1. Introduction

In Kedex Props., LLC v. Trisura Specialty Ins. Co. (2026 NY Slip Op 01345), the Appellate Division, Second Department, addressed a familiar but frequently litigated divide in liability insurance coverage: the insurer’s broad duty to defend versus the narrower duty to indemnify.

The plaintiff-insured, Kedex Properties, LLC (“Kedex”), owned property in Jackson Heights. After a fire, Kedex retained a restoration contractor, which in turn involved scaffolding work. A worker, Anibal Fernando Cabrera Ochoa, allegedly fell from a scaffold and sued Kedex in the underlying personal injury action, Ochoa v Kedex Properties, LLC, asserting negligence and Labor Law violations. Kedex tendered defense and indemnity to its commercial general liability carrier, Trisura Specialty Insurance Company (“Trisura”). Trisura disclaimed, citing multiple exclusions (employer’s liability, construction, workers’ compensation, and medical payments exclusions).

The coverage action sought declaratory relief compelling Trisura to defend and indemnify. The Supreme Court denied Kedex’s summary judgment motion in full. On appeal, the Second Department modified: it granted summary judgment to Kedex on the duty to defend, but affirmed denial as to indemnity because material facts remained unresolved.

Key issues: (i) whether the underlying allegations triggered coverage as an “occurrence,” and (ii) whether Trisura could defeat the duty to defend (and obtain a declaration of no indemnity) based on exclusions, where factual disputes remained about the nature of the work and the claimant’s employment status.

2. Summary of the Opinion

  • Duty to defend: The court held Kedex established prima facie coverage because the alleged fall constituted an “occurrence” (“an accident”) during the policy period, and Trisura failed to show the underlying pleadings fell “solely and entirely” within the relied-upon exclusions. Trisura therefore must defend Kedex in Ochoa v Kedex Properties, LLC.
  • Duty to indemnify: The court held Kedex did not eliminate triable issues of fact relevant to exclusions—especially whether the work included demolition (implicating the construction exclusion) and whether Ochoa was Kedex’s employee within the policy’s meaning (implicating employer’s liability and workers’ compensation exclusions). Summary judgment on indemnity was properly denied.
  • Procedural declaratory relief: Because the action is for declaratory judgment, the matter was remitted for entry of a judgment declaring the defense obligation.

3. Analysis

A. Precedents Cited

1) Burden allocation: coverage first, exclusions second

The decision begins with the orthodox burden framework:

  • County of Suffolk v Ironshore Indem., Inc. — cited for the principle that the insured bears the initial burden to show coverage, while the insurer bears the burden to prove an exclusion defeats coverage.
  • Consoldated Edison Co. of N.Y. v Allstate Ins. Co. — reinforces that once an insured shows the loss arises from an “accident”/“occurrence,” the insurer must prove an exclusion applies.

These cases anchor the Second Department’s approach: Kedex had to show an “occurrence”; after that, Trisura had to demonstrate that exclusions clearly and comprehensively negated the defense obligation on the face of the underlying allegations.

2) The “exceedingly broad” duty to defend

  • Mack-Cali Realty Corp. v NGM Ins. Co. — quoted for the proposition that the duty to defend is “exceedingly broad.”
  • Regal Constr. Corp v National Union Fire Ins. Co. of Pittsburgh, PA — the foundational Court of Appeals authority used (via Mack-Cali) to describe the breadth of the defense duty.
  • BP A.C. Corp. v One Beacon Ins. Group — cited for the “even potentially within the protection purchased” / “reasonable possibility of coverage” framing.

The court applied these precedents to treat the defense duty as allegation-driven: if the underlying pleadings could be read to fall within coverage, the insurer must defend—unless exclusions unmistakably foreclose coverage under every reasonable reading.

3) The insurer’s heavy burden when relying on exclusions

  • Automobile Ins. Co. of Hartford v Cook — supplies the controlling standard: the insurer must show the complaint “solely and entirely” falls within exclusions and is “subject to no other interpretation.”
  • Gem-Quality Corp. v Colony Ins. Co. — applied for the same “solely within exclusions” test, emphasizing the insurer’s burden at the defense stage.
  • Grenadier Realty Corp. v RLI Ins. Co. and East Ramapo Cent. Sch. Dist. v New York Schs. Ins. Reciprocal — invoked for strict, narrow construction of exclusions.
  • Essex Ins. Co v George E. Vickers, Jr., Enters., Inc. — underscores that if an exclusion could “even potentially” be inapplicable, the insurer must defend.

Using these authorities, the Second Department concluded Trisura did not carry its burden to defeat the defense obligation at summary judgment—because the exclusions depended on facts not conclusively established by the underlying pleadings or the record on the motion.

4) Defense versus indemnity: distinct inquiries

  • One Reason Rd., LLC v Seneca Ins. Co., Inc. — cited for the core point that the duty to defend is broader than the duty to indemnify, and that factual issues may remain on indemnity even when a defense is owed.
  • Mapfre Ins. Co. of N.Y. v Ferrall — cited for the principle that indemnity depends on whether the insured is liable for a covered loss.
  • Matter of Progressive Dr. Ins. v Malone and Harleysville Ins. Co. v United Fire Protection, Inc. — used to support denial of indemnity where triable facts bear on exclusion application (here, demolition/construction scope and employment status).

5) Declaratory judgment procedure

  • Lanza v Wagner — cited for the procedural directive that, in a declaratory judgment action, the court should remit for entry of a proper declaratory judgment (rather than leaving the outcome as a mere order).

B. Legal Reasoning

1) Prima facie coverage: an “occurrence” was shown

Kedex met its initial burden by submitting the policy and showing the claim involved “bodily injury” caused by an “occurrence,” defined as “an accident,” within the policy period. Critically, Kedex also submitted a letter from counsel for Trisura’s third-party administrator indicating that Ochoa’s bodily injury fell within the policy’s “occurrence” definition and thus triggered coverage.

On that record, the court held Kedex established prima facie that the underlying complaint alleged an “occurrence” within the policy’s insuring agreement, satisfying the first step under County of Suffolk v Ironshore Indem., Inc. and Consoldated Edison Co. of N.Y. v Allstate Ins. Co..

2) Why exclusions did not defeat the duty to defend at summary judgment

Trisura disclaimed based on multiple exclusions, but to avoid defending it needed to meet the demanding Automobile Ins. Co. of Hartford v Cook standard: the underlying allegations must fall “solely and entirely” within exclusions and permit “no other interpretation.”

The Second Department concluded Trisura failed to make that showing. The allegations (and record on the motion) did not conclusively establish the facts necessary to place the claim entirely within the exclusions. Because the exclusions could “even potentially” be inapplicable, Trisura’s duty to defend attached under BP A.C. Corp. v One Beacon Ins. Group and Essex Ins. Co v George E. Vickers, Jr., Enters., Inc.. The court therefore modified the order to grant a defense declaration.

3) Why indemnity could not be declared on this record

The court drew a sharp line between defense (allegation-based) and indemnity (liability and fact-based). Even with a defense owed, indemnity requires resolution of facts bearing on coverage and exclusions.

The court identified specific unresolved fact issues:

  • Whether the work’s scope included demolition, which could trigger the construction exclusion; and
  • Whether Ochoa was an employee of Kedex “within the meaning of the policy,” potentially triggering the employer’s liability and workers’ compensation exclusions.

Because Kedex, as the summary judgment movant, failed to eliminate these triable issues, the court affirmed denial of summary judgment as to indemnity, consistent with One Reason Rd., LLC v Seneca Ins. Co., Inc. and Mapfre Ins. Co. of N.Y. v Ferrall.

C. Impact

  • Reinforces the “pleading-plus” reality of defense disputes: Insurers seeking to avoid a defense on exclusions must show that the underlying allegations (and any permissible coverage materials) foreclose every reasonable covered interpretation. Where exclusions hinge on work scope (e.g., whether “demolition” occurred) or employment status, the duty to defend will often be triggered pending factual development.
  • Encourages careful drafting and evidentiary support for disclaimer: Broad, multi-exclusion disclaimers may fail at the defense stage if they depend on contested facts. The decision signals that a disclaimer premised on exclusions will be vulnerable unless the insurer can tie the underlying allegations unequivocally to the exclusion elements.
  • Separates strategic victories: Policyholders can win an early defense declaration even when indemnity remains uncertain. Conversely, insurers may be compelled to fund defense while litigating indemnity through discovery, motion practice, or post-liability proceedings.

4. Complex Concepts Simplified

“Occurrence” / “accident”
A triggering event for CGL coverage. Here, a worker’s fall and injury is typically treated as accidental from the insured’s standpoint, satisfying the “occurrence” requirement.
Duty to defend vs. duty to indemnify
The duty to defend is based on whether the allegations (even potentially) fit within coverage. The duty to indemnify depends on what actually happened and whether the insured is liable for a covered loss after facts are determined.
Exclusions “solely and entirely” applying
To avoid defending, the insurer must show the claim can only be read as excluded—there is no reasonable reading under which coverage might apply.
Strict construction of exclusions
Exclusions are read narrowly; ambiguities and close calls tend to be resolved in favor of preserving coverage—especially the defense obligation.
Triable issue of fact
A genuine factual dispute requiring evidence and fact-finding. Here, disputes about whether “demolition” occurred and about employment status prevented an indemnity declaration at summary judgment.

5. Conclusion

Kedex Props., LLC v. Trisura Specialty Ins. Co. reaffirms a central New York coverage principle: once an insured shows an “occurrence,” an insurer can avoid the duty to defend only by proving the underlying allegations fall entirely within exclusions and admit no other reasonable interpretation. At the same time, the decision underscores that indemnity is not resolved by the breadth of defense standards; where exclusion application turns on disputed facts (such as the presence of demolition work or the claimant’s employment relationship), indemnity must await factual development.