On September 11, 2025, the Appellate Division, First Department, issued a decision reversing a lower court’s denial of a preliminary injunction sought by New York Marine and General Insurance Company. The case arose when New York Marine, acting as plaintiff, asked the court to compel Millennia Assurance, Inc. to deposit $4,753,758.02 into a trust account. The insurer argued that a collateral shortfall had resulted in a statutory Schedule F penalty from a state regulator in 2022. This penalty, according to New York Marine, reduced its total policyholder surplus and undermined its ability to issue or reinsure federal bonds.