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Roman Catholic Diocese of Brooklyn v. National Union Fire Insurance
New York Court of Appeals (2013) | 21 N.Y.3d 139; 991 N.E.2d 666
TL;DR: The Diocese sought insurance reimbursement for a settlement of alleged repeated sexual abuse by a priest. The court affirmed that the alleged incidents constituted multiple occurrences requiring separate self-insured retentions, and that potential liability must be allocated pro rata across seven policy periods. Coverage defenses remained unresolved.
Legal Significance: The decision applies the unfortunate event test to repeated sexual abuse claims, treating distinct incidents as separate occurrences under these policies. It also distinguishes coverage limitations from exclusions requiring timely disclaimer and applies pro rata allocation when injuries cannot be assigned precisely to policy periods.