Was the insurer validly served with process, and does the court have personal jurisdiction over it?

Short answer: Settled at the Appellate Division, no conflicting department. The rules are settled and applied, not disputed. Second Department (Appellate Division and the Appellate Term, which decides most of these cases): service on the Superintendent under Insurance Law § 1212 binds an authorized insurer and a bare denial of receipt does not rebut it (NY & Presbyt. Hosp. 2006, Hospital for Joint Diseases 2008, Montefiore 2008, Westchester Med. Ctr. 2010); CPLR 312-a service is incomplete without a signed acknowledgment (Gateway 2011, Hellander 2015, Longevity 2020 and many companions); an out-of-state insurer not authorized here and not transacting business here is outside the courts' reach, the plaintiff bears the burden and needs tangible evidence for jurisdictional discovery (Eagle Ins. Co. v Gutierrez-Guzman, 21 AD3d 489 [2005], not in the database; NYC Med. 2004, Compas 2015, Flatlands 2014, Pavlova 2018 and the 2019 American Independent series); lack of personal jurisdiction is no ground to stay a no-fault arbitration (Art of Healing 2013). No Court of Appeals decision on this question is in the database; the governing Court of Appeals rules are general CPLR law (Fischbarg v Doucet, Peterson v Spartan Indus., Fashion Page, Gager v White, Pohlers). The only friction found is at trial level: a 2006 Supreme Court, New York County decision (Heights Chiropractic, 9780) vacated a no-fault arbitration award for lack of jurisdiction over the out-of-state insurer, while the Second Department later held personal jurisdiction is not required for arbitration; and a First Department decision (CURE v Mian 2021) treated the insurer's amenability to arbitration as an issue of fact under Insurance Law § 5107.

Scope. Deciding this question means ruling on whether a no-fault insurer (including a self-insurer such as a rental company or transit authority, MVAIC, or an out-of-state fund) that is sued by a provider or claimant, or named as respondent in an article 75 or inter-insurer proceeding, was brought under the court's power: whether service on it was valid (service on the Superintendent of Insurance / DFS under Insurance Law § 1212, on a registered agent, officer or authorized employee under CPLR 311 [a] [1], mail service under CPLR 312-a, VTL § 253, the territorial limits of CCA/UDCA 403-404, the 120-day rule of CPLR 306-b, filing of proof of service), whether the insurer rebutted the process server's affidavit or a traverse hearing is needed, and whether an out-of-state insurer is subject to New York jurisdiction at all (Insurance Law §§ 1212-1213, CCA 404 / CPLR 301-302 long-arm, jurisdictional discovery under CPLR 3211 [d]). It also covers rulings that the insurer waived the objection (CPLR 3211 [e], 320 [b], participation in the litigation) and rulings on whether personal jurisdiction over an out-of-state insurer is needed for, or defeats, no-fault arbitration. Categories record what the court held on service/jurisdiction over the insurer, not who won the case.

Based on 137 decisions in our database, the most recent decided September 23, 2026.

Leading authorities · Governing regulations · Authority map · Decisions by court · Plain-text version (Markdown)

Leading authorities

Montefiore Med. Ctr. v Auto One Ins. Co. (2008 NY Slip Op 10596) Appellate Division, Second Department, 2008§ 1212 service binds insurer; bare denial of receipt failsService by delivery to the Assistant Deputy Superintendent and Chief of Insurance under Insurance Law § 1212 was proper; the insurer did not claim its address on file was wrong, and its mere denial of receipt did not rebut the presumption created by the affidavit of service. Vacatur was denied under both CPLR 5015 (a) (1) and CPLR 317.
The defendant did not contend that the address on file with the Superintendent of Insurance was incorrect, and the mere denial of receipt of the summons and complaint was insufficient to rebut the presumption of proper service created by the affidavit of service
American Ind. Ins. Co. v Art of Healing Medicine, P.C. (2013 NY Slip Op 01546) Appellate Division, Second Department, 2013No personal jurisdiction needed for no-fault arbitrationLack of personal jurisdiction over an out-of-state insurer (American Independent) is not a ground under CPLR 7503 (b) to permanently stay no-fault arbitration; the question is the arbitrator's authority under the policy, and Gutierrez-Guzman and Basedow apply only where a court proceeding seeks to bind the insurer.
In short, personal jurisdiction is not required for arbitration that is controlled by the parties’ agreement. Therefore, the Supreme Court erred in granting the petition to permanently stay arbitration on the ground that there was no personal jurisdiction over AIIC.
Later history: In a second proceeding over the same claims, Matter of American Ind. Ins. Co. v Nova Acupuncture, P.C. (2d Dept 2016, post 5196) held AIIC was not barred from contesting arbitrability under Insurance Law § 5107 and remitted for a hearing on common control with an authorized insurer.
NYC Med. & Neurodiagnostic, P.C. v Republic W. Ins. Co. (2004 NY Slip Op 24526) Appellate Term, Second Department, 2004Plaintiff's burden; discovery only on tangible 'sufficient start'Where an out-of-state insurer served through the Superintendent showed it was not doing business in New York City, the plaintiff bore the burden of showing jurisdiction; conclusory allegations on information and belief were not the 'sufficient start' needed for jurisdictional discovery under CPLR 3211 (d) and Insurance Law § 1213, so the complaint had to be dismissed. The court below also erred by doing its own Internet research.
In order to demonstrate that “facts essential to justify opposition [to the motion to dismiss] may exist” (CPLR 3211 [d]), plaintiff needed to make more than conclusory allegations, and needed to submit some tangible evidence to substantiate its allegations
Later history: Reverses the Civil Court, Queens County order; the majority said that court's later decision on reargument (3 Misc 3d 925, 2004 NY Slip Op 24115, post 10444) should not be followed. Pesce, P.J., dissented (the court could notice from the Insurance Department's website that the insurer was licensed, so § 1212 service conferred jurisdiction).
Flatlands Med., P.C. v AAA Ins. (2014 NY Slip Op 24048) Appellate Term, Second Department, 2014Unauthorized out-of-state insurer: no §§ 1212-1213 or long-arm jurisdictionAn out-of-state insurer that showed it was not authorized in New York and wrote no business here could not be reached through service on the Superintendent under Insurance Law § 1212 or § 1213, nor under CCA 404; the insured's driving into New York was not enough, and the plaintiff offered no evidentiary facts, so jurisdiction was never acquired.
We further note that the mere unilateral act of an automobile insurer’s insured of driving into New York State, without more, is insufficient to permit a New York court to exercise long-arm jurisdiction over the out-of-state insurer
Pavlova v American Ind. Ins. Co. (2018 NY Slip Op 50943(U)) Appellate Term, Second Department, 2018Counsel's affirmation cannot show long-arm jurisdiction over insurerAmerican Independent's employees' affidavits made a prima facie showing that the Civil Court lacked personal jurisdiction over the Pennsylvania insurer; plaintiff's attorney's affirmation, made without personal knowledge, did not make the prima facie showing of jurisdiction under CCA 404 (a), so the CPLR 3211 (a) (8) motion was granted.
In the case at bar, the affirmation of plaintiff’s attorney was insufficient to demonstrate that personal jurisdiction over defendant existed under the Civil Court’s long-arm statute (see CCA 404 [a]), as plaintiff’s counsel failed to establish that he possessed personal knowledge of the facts.
Richard A. Hellander, M.D., P.C. v Metlife Auto & Home Ins. Co. (2015 NY Slip Op 25164) Appellate Term, Second Department, 2015CPLR 312-a service incomplete without signed acknowledgmentMail service under CPLR 312-a was never completed because the insurer never signed and returned the acknowledgment of receipt and the plaintiff tried no other method; an answer pleading the jurisdictional defense was not an appearance, and with no action pending the insurer did not waive the defense by not moving within 60 days (CPLR 3211 [e]).
The record in the present case reveals that an acknowledgment of receipt was never signed by defendant and returned to plaintiff. Consequently, plaintiff was required to effect personal service in another manner (see CPLR 312-a [e]; Dominguez v Stimpson Mfg. Corp., 207 AD2d 375 [1994]).
Matter of Eagle Ins. Co. v Gutierrez-Guzman 21 AD3d 489No long-arm jurisdiction over out-of-state insurer American Independent; the insured's unilateral act of driving into New York is not enough. Cited by 23 decisions in the database (the 2019 American Independent series, Flatlands, Healthwise).Not in our database.
Matter of Government Empls. Ins. Co. v Basedow 28 AD3d 766Dismissed for lack of personal jurisdiction a petition to add the out-of-state insurer as a party; distinguished in Art of Healing.Not in our database.
Fischbarg v Doucet 9 NY3d 375The party asserting jurisdiction bears the burden of proof; cited in RAZ (7610), JC Healing Touch (6104), Flatbush (5928), Dakiroks (19237).Not in our database.
Peterson v Spartan Indus. 33 NY2d 463Jurisdictional discovery requires a non-frivolous 'sufficient start'; cited in NYC Med., Compas, Nica, Vladenn.Not in our database.
Fashion Page v Zurich Ins. Co. 50 NY2d 265Corporate service sustained where the process server reasonably relies on an employee's claim of authority (Pain Mgt. Ctr. of N.J., 17366).Not in our database.
Gager v White 53 NY2d 475An unraised personal-jurisdiction objection is waived by participating in the litigation (Central Radiology 6278, Masigla 2971, Charles Deng 2555).Not in our database.
Pohlers v Exeter Mfg. Co. 293 NY 274Service on a state officer designated by consent is valid beyond a local court's territorial limits; basis of the Buffalo § 1212 decisions (8352, 8390).Not in our database.
Dominguez v Stimpson Mfg. Corp. 207 AD2d 375If the CPLR 312-a acknowledgment is not returned, the plaintiff must serve another way; cited in Gateway, St. Dominick, Hellander, Active Care.Not in our database.
Matter of Star Boxing, Inc. v DaimlerChrysler Motors Corp. 17 AD3d 372A notice of petition must be served like a summons (CPLR 403 [c]); cited for article 75 petitions served on an insurer's attorney (R.J. Professional 9170, Eagle v Republic W. 8478).Not in our database.
Rosa v Allstate Ins. Co. 981 F2d 669Cited by Torres-Jimenez, Delacruz-Gomez and Dakiroks for VTL § 253 not reaching an insurer.Not in our database.

Governing regulations

Governed by the CPLR (301, 302, 306-b, 311, 312-a, 3211), Insurance Law §§ 1212 and 1213, Vehicle and Traffic Law § 253 and the court acts (CCA and UDCA 403, 404), not by Part 65.

Chosen by us from the regulation text and the decisions on this question that cite it. Each link opens our copy of the regulation, which is unofficial; the official text is in the NYCRR.

Authority map

Each circle is a decision on this question, placed by court and date; its colour is the position it took. Lines are citations between them. Select a circle (or find a decision by name) to see its links and summary. The same decisions are listed by court below the map.

Insurer validly served and subject to the court's jurisdiction, or service defect cured/excusedMethod, place, timing or proof of service on the insurer failed, so no jurisdiction was obtainedInsurer (usually out-of-state) not subject to the forum's jurisdiction; plaintiff did not show a basisTriable issue on service or jurisdiction: traverse hearing, hearing, discovery or trial orderedInsurer's objection fails without reaching service or contacts: waived, forfeited, or jurisdiction not requiredRing: rules on the question, but another ground decided the caseContrasted, distinguished or limitedDeclined to follow, questioned, overruled or reversedCited Show ordinary citations

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How the rule was applied, by court

Court	Jurisdiction upheld	Service defective	No jurisdiction over insurer	Hearing or discovery needed	Objection waived/not required	Total
Appellate Division, First Department	0	1	0	1	0	2
Appellate Division, Second Department	5	0	0	0	1	6
Appellate Term, First Department	0	0	0	0	1	1
Appellate Term, Second Department	21	26	55	3	3	108
Trial courts in the First Department	1	0	1	0	1	3
Trial courts in the Second Department	5	8	2	0	0	15
Trial courts in the Fourth Department	2	0	0	0	0	2

Decisions (137)

Every decision in our database that rules on this question: highest court first, then by department, newest first. 106 turn on it; the others rule on it alongside a different main ground (marked "also decides"). The one-sentence summaries describe what each court said on this question.

Appellate Division, First Department (2 decisions)

Matter of Floral Park Drugs, Inc. v Nationwide Gen. Ins. Co. (2024 NY Slip Op 01114) Appellate Division, First Department, February 29, 2024Method, place, timing or proof of service on the insurer failed, so no jurisdiction was obtained (also decides)Held the affidavit of mail service of the petition on the insurer facially defective under CPLR 312-a because it did not state that two copies of the statement and acknowledgment of receipt were served.
CURE (Citizens United Reciprocal Exch.) v Mian (2021 NY Slip Op 04100) Appellate Division, First Department, June 29, 2021Triable issue on service or jurisdiction: traverse hearing, hearing, discovery or trial orderedDenied renewal of the out-of-state insurer's summary judgment motion on its lack-of-jurisdiction defense because the new evidence left an issue of fact whether it was under common control with an insurer transacting business in New York.

Appellate Division, Second Department (6 decisions)

American Ind. Ins. Co. v Art of Healing Medicine, P.C. (2013 NY Slip Op 01546) Leading case Appellate Division, Second Department, March 13, 2013Insurer's objection fails without reaching service or contacts: waived, forfeited, or jurisdiction not requiredHeld lack of personal jurisdiction over the out-of-state insurer was no CPLR 7503 ground to stay no-fault arbitration, because personal jurisdiction is required for judicial power, not for arbitration controlled by the policy.
Westchester Med. Ctr. v Philadelphia Indem. Ins. Co. (2010 NY Slip Op 00138) Appellate Division, Second Department, January 5, 2010Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Treated service through the Superintendent under Insurance Law § 1212, who acknowledged service and notified the insurer's Pennsylvania office, as established, so the insurer's no-record affidavit did not excuse its default.
Montefiore Med. Ctr. v Auto One Ins. Co. (2008 NY Slip Op 10596) Leading case Appellate Division, Second Department, December 30, 2008Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held service by delivery to the Superintendent of Insurance under Insurance Law § 1212 was proper, the insurer did not claim its address on file was wrong, and its bare denial of receipt did not rebut the presumption.
Hospital for Joint Diseases v Lincoln Gen. Ins. Co. (2008 NY Slip Op 07619) Appellate Division, Second Department, October 7, 2008Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held service was effectuated by delivery to the Assistant Deputy Superintendent under Insurance Law § 1212, so the motion could be treated under CPLR 317.
New York & Presbyt. Hosp. v Allstate Ins. Co. (2006 NY Slip Op 04260) Appellate Division, Second Department, May 30, 2006Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held service was effectuated by delivery to the Deputy Secretary of Insurance under Insurance Law § 1212, which is not personal delivery, so CPLR 317 applied.
Matter of Hanover Ins. Co. v Cannon Express Corp. (2003 NY Slip Op 18042) Appellate Division, Second Department, November 3, 2003Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held the out-of-state self-insurer respondent was subject to the court's personal jurisdiction because the unrebutted affidavit of service was prima facie proof of proper service under CPLR 311 (a) (1).

Appellate Term, First Department (1 decision)

Globe Med. Care O.L.P.C. v Travelers Ins. Co. (2010 NY Slip Op 50020(U)) Appellate Term, First Department, January 11, 2010Insurer's objection fails without reaching service or contacts: waived, forfeited, or jurisdiction not requiredHeld dismissal at trial for failure to file proof of service was error because the insurer never raised that objection and so waived it; alternatively the omission was an irregularity correctable nunc pro tunc.

Appellate Term, Second Department (108 decisions)

Midwood Metro. Med., P.C. v Permanent Gen. Assur. Corp. (2026 NY Slip Op 51589(U)) Appellate Term, Second Department, September 18, 2026Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held the process server's affidavit was prima facie proof of proper CPLR 311 (a) (1) service on the insurer's registered agent, unrebutted by an affidavit from someone with personal knowledge.
Shamayim Chiropractic, P.C. v Permanent Gen. Assur. Corp. (2026 NY Slip Op 50791(U)) Appellate Term, Second Department, May 15, 2026Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held the process server's affidavit of delivery to the managing agent of the insurer's registered agent was prima facie proof of proper CPLR 311 (a) (1) service, unrebutted by the insurer's conclusory nonreceipt claim.
LV Med. Diagnostic Servs., P.C. v Safe Auto Ins. Co. (2025 NY Slip Op 51974(U)) Appellate Term, Second Department, December 5, 2025Triable issue on service or jurisdiction: traverse hearing, hearing, discovery or trial orderedUpheld denial of the out-of-state insurer's CPLR 3211 (a) (8) motion because its proof was inadmissible and issues of fact existed on whether it did business in New York, leaving personal jurisdiction for trial.
Pyramid Care, P.T., P.C. v Safe Auto Ins. Co. (2025 NY Slip Op 51981(U)) Appellate Term, Second Department, December 5, 2025Triable issue on service or jurisdiction: traverse hearing, hearing, discovery or trial orderedUpheld denial of the out-of-state insurer's CPLR 3211 (a) (8) motion because its proof was inadmissible and issues of fact existed on whether it did business in New York, leaving personal jurisdiction for trial.
Harvey Family Chiropractic, Physical Therapy & Acupuncture, PLLC v Liberty Lines Tr., Inc. (2024 NY Slip Op 24113) Appellate Term, Second Department, March 22, 2024Insurer validly served and subject to the court's jurisdiction, or service defect cured/excusedHeld the transit company's CPLR 3211 (a) (8) motion properly denied because its president's affidavit, saying only it had no office or business in Kings County, did not exclude valid Secretary of State service under Business Corporation Law § 306 (c) or CCA 404.
Art of Healing Medicine, P.C. v Allstate Ins. Co. (2023 NY Slip Op 51471(U)) Appellate Term, Second Department, December 22, 2023Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held the insurer's no-record claim of nonreceipt did not rebut the process server's affidavit of delivery to an authorized employee, absent an affidavit from that employee or an explanation for its absence.
Tam Med. Supply Corp. v American Ind. Ins. Co. (2022 NY Slip Op 50913(U)) Appellate Term, Second Department, September 9, 2022Method, place, timing or proof of service on the insurer failed, so no jurisdiction was obtainedHeld personal jurisdiction was not obtained over the insurers because the summons and complaint were served by mail under CPLR 312-a and no acknowledgment of service was shown, so the complaint was dismissed as against them.
Shafai Acupuncture, P.C. v State Farm Mut. Auto. Ins. Co. (2022 NY Slip Op 50907(U)) Appellate Term, Second Department, August 19, 2022Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held that the plaintiff's late service on the insurer, made after the 120-day period of CPLR 306-b, should have been deemed to satisfy the order directing service, since that order implicitly extended the time to serve; the complaint was then dismissed on res judicata.

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Trial courts in the First Department (3 decisions)

Chubb Ins. Co. v GEICO Ins. Co. (2008 NY Slip Op 51985(U)) Supreme Court, New York County, September 29, 2008Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Held the insurer validly served under Insurance Law § 1212 by delivery to the Superintendent's designee, with acknowledgment and forwarding, and its unsupported claim that its files showed no service did not controvert the affidavit.
American Ind. Ins. v Heights Chiropractic Care, P.C. (2006 NY Slip Op 26096) Supreme Court, New York County, January 17, 2006Insurer (usually out-of-state) not subject to the forum's jurisdiction; plaintiff did not show a basisHeld the unlicensed Pennsylvania insurer not subject to New York jurisdiction or no-fault arbitration because partial payment of bills was not systematic business under the long-arm statute and Insurance Law § 1213 did not benefit an assignee provider.
American Ind. Ins. v Gerard Ave. Med. P.C. (2005 NY Slip Op 52302(U)) Supreme Court, Bronx County, December 31, 2005Insurer's objection fails without reaching service or contacts: waived, forfeited, or jurisdiction not requiredHeld that the court's possible lack of personal jurisdiction over the out-of-state insurer was not the question; the arbitrator's power depended on whether the policy was subject to New York's no-fault arbitration, which the record did not show.

Trial courts in the Second Department (15 decisions)

Dakiroks Prods., Corp v United Auto. Ins. Co. (2026 NY Slip Op 51811(U)) Civil Court of the City of New York, Kings County, September 23, 2026Method, place, timing or proof of service on the insurer failed, so no jurisdiction was obtainedHeld the action dismissed without prejudice because the affidavit of service under VTL § 253 was facially void as to a no-fault insurer and later service was attempted beyond 120 days without leave under CPLR 306-b.
Delacruz-Gomez v New Jersey Mfrs. Ins. Co. (2026 NY Slip Op 50999(U)) Civil Court of the City of New York, Kings County, June 26, 2026Method, place, timing or proof of service on the insurer failed, so no jurisdiction was obtainedHeld service under VTL 253 void on its face because the nonresident insurer was neither an owner nor operator, so personal jurisdiction was never obtained; rejected the argument that the rejected answer waived the defense.
Healthwise Med. Assoc., P.C. v Safe Auto Ins. Co. (2026 NY Slip Op 50986(U)) Civil Court of the City of New York, Kings County, March 5, 2026Insurer (usually out-of-state) not subject to the forum's jurisdiction; plaintiff did not show a basisDismissed because the unauthorized out-of-state insurer, whose policy was issued in Pennsylvania, showed it transacted no business in New York, and the provider's speculation about policy language made no sufficient start toward long-arm jurisdiction; the service challenge was rejected.
ENS Med., P.C. v Nationwide Ins. Co. (2026 NY Slip Op 26033) Supreme Court, Kings County, February 13, 2026Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Rejected the insurer's objection to defective CPLR 312-a service, deeming the commencement papers properly and timely served nunc pro tunc because the insurer did not refute its agent's acceptance of mail service and suffered no prejudice.
Pedro Torres-Jimenez MD, P.C. v American Access Cas. Co. (2025 NY Slip Op 50358(U)) Civil Court of the City of New York, Kings County, March 13, 2025Method, place, timing or proof of service on the insurer failed, so no jurisdiction was obtainedHeld service on the Illinois insurer under VTL 253 void on its face because the statute reaches only nonresident owners or operators, so the court lacked personal jurisdiction, denied the default judgment and dismissed without prejudice.
Pak Hong Sik MD Med. Care, P.C. v Omni Ins. Co. (2023 NY Slip Op 50431(U)) Civil Court of the City of New York, Richmond County, May 10, 2023Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Denied the out-of-state insurer's motion to dismiss for lack of personal jurisdiction as a barred successive pre-answer motion and, alternatively, because its stale affidavit and inadmissible website printout failed to show it transacted no New York business.
Action Potiential Chiropractic, PC v Grange Mut. Cas. Ins. Co. (2021 NY Slip Op 51306(U)) Civil Court of the City of New York, Kings County, June 29, 2021Method, place, timing or proof of service on the insurer failed, so no jurisdiction was obtained (also decides)Denied leave to substitute a new insurer under CPLR 305 (c) because nothing showed that the original or the intended insurer had been served, so the court lacked jurisdiction over it; the time-barred claim also failed to relate back.
Orman v GEICO Gen. Ins. Co. (2012 NY Slip Op 52205(U)) Supreme Court, Kings County, November 30, 2012Insurer validly served and subject to the court's jurisdiction, or service defect cured/excused (also decides)Struck the insurer's personal-jurisdiction defense because the proof of service, fee receipt and Insurance Department acknowledgment showed service under Insurance Law § 1212, and the insurer did not oppose.

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Trial courts in the Fourth Department (2 decisions)

Buffalo Gen. Hosp. v Erie Ins. Co. (2009 NY Slip Op 29438) County Court, Erie County, September 24, 2009Insurer validly served and subject to the court's jurisdiction, or service defect cured/excusedHeld service of Buffalo City Court process on the Superintendent of Insurance in Albany valid under Insurance Law § 1212, because authorized insurers consented to such service by filing a power of attorney, overriding constitutional territorial limits.
Daniel C. Cox, D.C., P.C. v State Farm Gen. Ins. (2009 NY Slip Op 29066) City Court of Buffalo, January 21, 2009Insurer validly served and subject to the court's jurisdiction, or service defect cured/excusedHeld that service on the Superintendent of Insurance in Albany or New York City under Insurance Law § 1212 gave the Buffalo City Court personal jurisdiction, because licensed insurers had consented to such service despite the constitutional territorial limits.

How this page is made: the decisions are those in our case-law database that cite this question's leading cases or were tagged with its subject. A language model read each one in full and recorded whether it rules on the question, the position it took and a one-sentence summary; a second, independent reading checked every entry. Court, department, date and the citation links come from the database. Read the decision before relying on it.