In Brown v. Poritsky (30 NY2d 289, 332 N.Y.S.2d 872 [1972]), the court discussed the liability of a special agent to his principal. In that case, the special agent failed to obtain insurance for properties owned by the principal, which were eventually destroyed by fire. The court did not address any contractual aspect of the relationship between the parties, nor was a breach of contract alleged. The Brown court stated that an agent may be liable to his principal for negligence.