Haas Tobacco Corp. v. America Fidelity Co

In Haas Tobacco Corp. v. America Fidelity Co. (226 NY 343, 123 N.E. 755 [1919]), the court recognized that while an insured might be "absolved from making the report required by its policy" in the case of a "trivial occurrence . . . if no apparent harm came from the mishap" (see id. at 344-45), where "a boy is knocked down in the street by an automobile, and at least slightly injured, the insured may not, without any investigation whatever, rely solely upon his own opinion or upon the opinion of his driver that because he went away the injury was too trivial to require attention" (see id. at 347.) These essentials have not changed over the past century.