The Supreme Court of New York granted the insured’s motion to compel the production of underwriting materials related to identifying additional insureds. Church of St. Andrew v. Western World Ins. Co., 2025 N.Y. Misc. LEXIS 7018 (N.Y. Sup. Ct. Aug. 5, 2025).

    The Church of St. Andrew (“church”) retained GC Solutions to perform roofing work at its premises. The church required GC Solutions to name it as an additional insured under its general liability policy. GC Solutions provided a Certificate of Insurance naming the church as an additional insured under the policy issued by Western World.

    While working on the roof, an employee of GC Solutions fell to his death. A wrongful death action was commenced by the decedent’s estate against the church. The church tendered its defense and indemnification to Western World. Western World disclaimed coverage, asserting that the church did not qualify as an additional insured under the policy.

    The church sued and served a set of interrogatories and document demands, requesting production of the underwriting guidelines governing additional insured endorsements. Western World refused to produce the information requested. The church moved to compel Western World to identify and produce the portions of its underwriting guidelines that pertained to additional insured coverage.

    Western World took the position that the church did not meet its internal criteria for coverage yet refused to disclose the very criteria it admitted set standards for coverage eligibility. Under such circumstances, the church was entitled to probe how Western World interpreted and applied the language in the endorsement in real-world underwriting practice.

    Prior New York case law held that underwriting materials were discoverable where they bore upon the scope of coverage and the application of policy language, even absent a claim of ambiguity. Here, the church did to seek speculative or broad-ranging discovery but instead requested limited portions of Western World’s underwriting guidelines that pertained specifically to how it defined and evaluated additional insured coverage. Such materials were directly relevant to the core dispute over whether the church qualified for coverage under the endorsement and whether Western World’s interpretation of the endorsement aligned with its own internal standards for coverage eligibility.

    Therefore, the church’s motion to compel was granted. Western World was ordered to produce portions of its underwriting guidelines  that pertained to additional insured coverage under its commercial liability policies.