In Siegel v. Spear  234 N.Y. 479, 138 N.E. 414 (N.Y. 1923), Seigel bought some furniture from Spear's company.  He then wanted Spear to store the furniture.  Spear's manager offered to store the furniture, and to get it insured.  No insurance was purchased and the warehouse burned down.  Siegel sued and won based on reliance.