New York’s Appellate Division, First Department has modified a July 29, 2024 order in interpleader litigation arising from Greenway Mews Realty, L.L.C. v Liberty Insurance Underwriters, Inc., 2025 NY Slip Op 06810. In its December 9, 2025 decision, the court held that Seneca Insurance Company’s motion to dismiss Federal Insurance Company’s unjust enrichment cause of action should have been denied, while upholding dismissal of Federal’s constructive trust claim.