In Planet Insurance Co. v. Bright Bay Classic Vehicles, 75 NY2d 394, 553 N.E.2d 562, 554 N.Y.S.2d 84 [1990], an endorsement to not cover rental cars leased for more than 12 months was deemed an exclusion when applied to give coverage to a vehicle leased for 24 months, where it was a fact that the owner of the car "paid an amount to cover liability insurance premiums," and the vehicle was "duly registered by the State of New York," which included a certificate filed with the Motor Vehicles Department indicating that the vehicle had proper insurance. (Id. at 398.)

In Planet Insurance, the finding that the endorsement limiting coverage to vehicles leased for less than 12 months, as a definition of rental vehicles, was actually an exclusion, was based on the public policy that the driver of the rental vehicle should have "no reason to suspect that he or she were putting either the public or him or herself at risk by causing an uninsured automobile to be operated on the highway." (Id. at 401.)