The Second Circuit reversed the district court’s dismissal of a negligence claim against the insured’s broker for failure to give notice to the insurer. Paro Management Co., Inc. v Willis of New Jersey, Inc., 2025 U.S. App. LEXIS 29289 (2nd Cir. Nov. 5, 2025).

Paro Management Company, Inc. sued its insurance broker, Willis of New Jersey, Inc,, for failing to deliver to Paro’s insurer a notice regarding the presence of lead paint on Paro’s residential property. Paro’s complaint alleged that it instructed Willis to convey the notice to its insurer and Willis promised to do so but did not follow through. Former tenants later sued Paro for damages arising from exposure to lead paint, and Paro’s insurer disclaimed coverage on the ground that it had not been timely notified of the lead paint issue. Paro then sued the insurer seeking a declaration of coverage. Both the former tenants’ lawsuit and the coverage action were pending in New York state court.