I neglected to write about Hoffend & Sons, Inc. v. Rose & Kiernan, Inc. that the New York Court of Appeals decided in June 2006 (see underlying decision from Appellate Division, Fourth Department).  The decision addresses a recurring issue: an policyholder’s action against his or her insurance broker for failing to secure the correct insurance.  In Hoffend, the insured claimed that the broker failed to obtain a policy that would have covered the loss involved.  The Court held, as a matter of law, that the policyholder did not establish that it made a specific request for the coverage in question or had a special relationship with the broker.