Is Being Named As An "Additional Insured" On An Insurance Endorsement Sufficient To Provide Coverage?

The New York Court of Appeals (New York's highest court) recently held that being named as an additional insured on a Certificate of Insurance might not, by itself, provide any coverage for additional insureds.

The Dormitory Authority of the State of New York ("DASNY") contracted with general contractor Samson Construction Company ("Samson") for construction of a new forensic laboratory for New York City. DASNY also contracted with a joint venture between Gilbane Building Company and TDX Construction Corporation (hereinafter, "Gilbane JV") for Gilbane JV to be the construction manager on the project. DASNY's contract with Samson provided that Samson would obtain general liability insurance for the job, with an endorsement naming as additional insureds as follows: "DASNY, the State of New York, the Construction Manager, Gilbane JV, and other entities specified on the Sample Certificate of Insurance provided by DASNY." The Sample Certificate of Insurance listed as