Key California Insurance Case Law: Bad Faith, Coverage, and Appraisal

California insurance law is built on case law. Statutes like Insurance Code § 790.03 and the Fair Claims Settlement Practices Regulations set minimum standards, but it is the courts that define what those standards mean in practice — what constitutes bad faith, how the “genuine dispute” doctrine works, what appraisal can and cannot resolve, and what damages a policyholder can recover when an insurer acts unreasonably.

This article surveys the most important California insurance cases in two categories: general insurance law (including bad faith and coverage/causation), and appraisal-specific case law. For each case, we explain the holding, its significance, and how it relates to the broader body of law. Whether you are a policyholder trying to understand your rights, a public adjuster building a claim file, or an attorney preparing for litigation, these are the cases you need to know.

Part One: General California Insurance and Bad Faith Case Law

1. Gruenberg v. Aetna Insurance Co. (1973) 9 Cal.3d 566

Gruenbergis the foundation of California insurance bad faith law. Max Gruenberg owned a bar in Los Angeles that burned down. He filed a claim with his insurer, Aetna. Instead of paying, Aetna worked with the arson investigators and the district attorney to have Gruenberg criminally charged with arson — charges that were later dismissed for lack of evidence. While the criminal charges were pending, Aetna denied the claim. Gruenberg sued.

The Holding: The California Supreme Court held that every insurance contract contains an implied covenant of good faith and fair dealing. When an insurer unreasonably refuses to pay benefits due under the policy, it breaches this covenant — and that breach sounds in tort, not just contract. This distinction is critical: because the claim is a tort claim, the policyholder can recover extra-contractual damages— including emotional distress and, in appropriate cases, punitive damages — that would not be available in a simple breach of contract action.

Significance: Gruenbergestablished three foundational principles that every subsequent California bad faith case builds upon: (1) the implied covenant of good faith and fair dealing exists in every insurance contract; (2) breach of that covenant is a tort, not merely a breach of contract; and (3) tort damages — including emotional distress and punitive damages — are available to the policyholder. Every case discussed in this article traces its lineage to Gruenberg.

2. Egan v. Mutual of Omaha (1979) 24 Cal.3d 809

Egan built on Gruenbergby establishing the standard for evaluating whether an insurer’s conduct constitutes bad faith. Robert Egan held a disability insurance policy with Mutual of Omaha. After he became disabled, the insurer repeatedly delayed, reduced, and terminated his benefits, relying on selective medical reviews and ignoring evidence that supported his claim.

The Holding: The California Supreme Court held that the test for bad faith is an objectivestandard: whether the insurer’s conduct was reasonable under the circumstances. The insurer’s subjective intent — whether it “meant” to act in bad faith — is irrelevant. The court also confirmed that punitive damagesare available in bad faith cases where the insurer’s conduct is sufficiently egregious, oppressive, or malicious.

Significance: Eganis important for two reasons. First, the objective standard means an insurer cannot defend itself by saying, “We genuinely believed we were right.” The question is not what the insurer believed but whether a reasonable insurer in the same position would have acted the same way. Second, the availability of punitive damages provides a powerful deterrent against the most egregious insurer misconduct. Together with Gruenberg, Egan established the two-part framework that governs California bad faith law to this day: the implied covenant creates the duty, and the objective standard measures compliance with it.

3. Waller v. Truck Insurance Exchange (1995) 11 Cal.4th 1

If Gruenberg and Egan are the sword, Walleris the shield. The “genuine dispute” doctrine — the most powerful defense available to insurers in bad faith cases — was established in this decision. The case involved a church that suffered fire damage and disputed the insurer’s valuation. When the policyholder sued for bad faith, the insurer argued that the disagreement over the loss amount was genuine and reasonable.

The Holding: The California Supreme Court held that an insurer is not liable for bad faith when there is a genuine disputeas to the insurer’s liability or the amount of the loss, so long as the insurer’s position is maintained in good faith and on reasonable grounds. In other words, an insurer that is wrongis not automatically acting in bad faith — as long as its position was reasonably held.

Significance: Wallercreated a safe harbor for insurers: if the insurer can show that its denial or reduced payment was based on a legitimate, reasonable interpretation of the facts or the policy, it can defeat a bad faith claim even if the denial turns out to be wrong. This doctrine does not require the insurer to be correct — only reasonable. Insurers rely heavily on this doctrine, and it is why they invest in building detailed claim files, hiring experts, and generating documentation that supports their position. Understanding Waller is essential because it defines what bad faith is not: a simple disagreement is not bad faith if the insurer’s position is reasonable.

4. Brandt v. Superior Court (1985) 37 Cal.3d 813

When an insurer acts in bad faith and the policyholder has to hire an attorney to recover the benefits owed under the policy, who pays for the attorney? In most American litigation, each side pays its own legal fees (the “American rule”). Brandt carved out an important exception for insurance bad faith cases.

The Holding:The California Supreme Court held that when an insurer’s bad faith conduct forces a policyholder to retain an attorney to obtain the policy benefits to which the policyholder was entitled, the attorney’s fees incurred in recovering those benefits are recoverable as compensatory damagesin the bad faith action. These are commonly known as “Brandt fees.”

Significance: Brandt fees fill a gap that would otherwise make bad faith litigation economically irrational for many policyholders. Without Brandt, a policyholder who was owed $50,000 in policy benefits and spent $30,000 in attorney’s fees to recover them would net only $20,000 — hardly an incentive to fight back. By making the attorney’s fees recoverable as part of the bad faith damages, Brandt ensures that policyholders can pursue bad faith claims without being punished for needing legal representation. Note that Brandtfees are compensatory damages, not a fee-shifting statute — they are part of the harm caused by the insurer’s bad faith.

5. Jordan v. Allstate Insurance Co. (2007) 148 Cal.App.4th 1062

Jordan addressed one of the most common forms of insurer misconduct: failing to properly investigate a claim before denying or underpaying it. The insured filed a theft claim, and Allstate denied it based on a superficial investigation that ignored substantial evidence supporting the claim.

The Holding: The court held that an insurer has an affirmative duty to thoroughly investigatea claim before making a coverage determination. The court emphasized that the insurer cannot hide behind the genuine dispute doctrine when the “dispute” was manufactured by the insurer’s own failure to investigate. The court also gave significant weight to the Fair Claims Settlement Practices Regulations (10 CCR § 2695) as evidence of the standard of care expected of insurers.

Significance: Jordan bridges the gap between the regulatory framework and the common law. The Fair Claims Regulations set detailed requirements for how insurers must investigate and handle claims. Jordanestablished that violations of those regulations are relevant — and potentially powerful — evidence that the insurer failed to meet its duty of good faith. For public adjusters and policyholders, this means that documenting regulatory violations is not just an administrative exercise — it is building the evidentiary foundation for a potential bad faith claim. Jordanalso limits the genuine dispute doctrine: an insurer cannot create a “dispute” by failing to look at the evidence and then claim the dispute was “genuine.”

6. Bock v. Hansen (2014) 230 Cal.App.4th 1273

Most bad faith cases target the insurance company itself. Bock asked a different question: can the individual claims adjuster be held personally liable?

The Holding: The court held that an individual insurance adjuster can be held personally liablefor conduct that constitutes an independent tort — for example, intentional misrepresentation, fraud, or intentional interference with the policyholder’s contractual rights. However, the adjuster is not liable for breach of the implied covenant itself, because the adjuster is not a party to the insurance contract. The adjuster’s liability must be based on conduct that independently violates a legal duty owed to the policyholder.

Significance: Bockmatters because it changes the incentive structure. If the individual adjuster can be named as a defendant — not just the insurance company — the adjuster has personal exposure and may be less willing to engage in the most egregious forms of misconduct. It also prevents the insurer from using individual adjusters as shields: “The adjuster made that decision, not us.” Where the adjuster’s conduct rises to the level of an independent tort, the policyholder can pursue both the company (for bad faith) and the adjuster (for the independent tort).

7. McCoy v. Progressive West Insurance Co. (2009) 171 Cal.App.4th 785

McCoy addresses a practice that infuriates policyholders: the insurer that withholds payment on the entire claim because it disputes part of the claim.

The Holding: The court held that when there is no genuine dispute about a portion of the claim, the insurer must pay the undisputed portion promptly. The insurer cannot withhold the entire payment simply because it disputes part of the claim. Withholding the undisputed amount is itself evidence of bad faith.

Significance: McCoy is one of the most practically important cases for policyholders and public adjusters. In real-world claims, insurers frequently withhold all payment while disputing a portion of the loss. For example, an insurer may agree that a roof has $80,000 in covered damage but refuse to pay anything because it disputes whether an additional $40,000 in interior damage is covered. Under McCoy, the insurer must pay the $80,000 it does not dispute while the $40,000 dispute is resolved. This principle also has strategic implications: when you demand the undisputed portion in writing and the insurer refuses to pay it, you are creating a contemporaneous record of bad faith.

8. Amadeo v. Principal Mutual Life Insurance Co. (9th Cir. 2003) 290 F.3d 1152

Amadeo is a Ninth Circuit case applying California law, and it provides an important counterpoint to Waller’s genuine dispute doctrine. While Waller protects insurers who maintain reasonable positions, Amadeo addresses what happens when the “dispute” is not genuine at all.

The Holding: The court held that the genuine dispute doctrine does not protect an insurer that manufactures a disputethrough biased investigation, selective reliance on evidence, or retention of experts whose conclusions are predetermined. A dispute is not “genuine” if the insurer created it by ignoring evidence, relying on biased experts, or failing to conduct a thorough investigation.

Significance: Amadeo closes the loophole that Waller might otherwise create. Without Amadeo, an insurer could deny a claim, hire a friendly expert to write a report supporting the denial, and then claim the denial was based on a “genuine dispute.” Amadeosays that this is not enough: the insurer’s investigation must be objectively reasonable, and the dispute must arise from a genuine evaluation of the evidence — not from an investigation designed to reach a predetermined conclusion. For public adjusters, Amadeo underscores the importance of documenting biased insurance experts and sham investigations: when the insurer’s “dispute” is based on a rigged investigation, the genuine dispute defense fails.

9. Garvey v. State Farm Fire & Casualty Co. (1989) 48 Cal.3d 395

The cases discussed above address how insurers must handle claims and what happens when they act unreasonably. Garveyaddresses a different but equally critical question: when multiple causes contribute to a loss — some covered, some excluded — how does a court determine whether the loss is covered at all? The California Supreme Court’s answer is the efficient proximate cause doctrine, and Garvey is its definitive statement.

The Facts:The policyholders suffered property damage caused by a combination of perils — some covered under the policy and some excluded. The insurer denied the claim by pointing to the excluded peril as a contributing cause, arguing that any involvement of an excluded cause defeated coverage. The question before the California Supreme Court was whether the insurer could deny the entire claim based on the presence of an excluded contributing cause when a covered peril was the predominant force behind the loss.

The Holding: The court held that when a covered peril and an excluded peril combine to cause a loss, coverage is determined by the efficient proximate cause— the predominant cause that sets the chain of events in motion. If the efficient proximate cause is a covered peril, the entire loss is covered, even if excluded perils contributed to the damage. Conversely, if the efficient proximate cause is an excluded peril, there is no coverage even if covered perils also played a role. The court rejected the insurer’s approach of parsing individual contributing causes and denying coverage whenever any excluded peril was involved. The focus must be on the single predominant cause — the one that set the loss in motion.

Building on Sabella: Garvey built on the foundation laid by Sabella v. Wisler (1963) 59 Cal.2d 21, which first articulated the efficient proximate cause analysis in California. Sabella established that when a loss results from a chain of causation, the court looks to the cause that predominates — the one that is the moving force behind the loss — rather than dissecting each link in the chain. Garvey took this principle and made it the definitive rule for concurrent causation disputes in California, resolving uncertainty about how Sabella applied to modern property insurance policies.

Anti-Concurrent Causation Clauses: One of the most significant practical consequences of Garvey is its effect on anti-concurrent causation (ACC) clauses— policy provisions that attempt to deny coverage whenever an excluded peril contributes to a loss in any way, regardless of whether it was the predominant cause. Insurers adopted ACC clauses specifically to override the efficient proximate cause doctrine. In California, these clauses are effectively unenforceable because they conflict with the Garvey/Sabellaframework and Insurance Code § 530. A carrier cannot use boilerplate policy language to circumvent a rule established by the California Supreme Court and grounded in the Insurance Code. Note, however, that other states may enforce ACC clauses — this protection is specific to California.

Significance: Garvey is critical in almost every property insurance claim where the cause of loss is disputed. Fire followed by water damage. Wind-driven rain and pre-existing wear and tear. Wildfire and subsequent mudslide. Earthquake and fire. In each scenario, the insurer will attempt to attribute the loss to an excluded cause. Garveytells us the correct analysis: identify the efficient proximate cause — the predominant force that set the loss in motion — and if that cause is covered, the loss is covered. The insurer cannot cherry-pick an excluded contributing cause to deny the claim. For policyholders and their representatives, Garvey is the case to cite whenever a carrier denies a claim by pointing to an excluded peril that was not the predominant cause of the loss.

How the Bad Faith and Coverage Cases Fit Together

These nine cases form a coherent framework. Gruenberg established the cause of action: the implied covenant and tort liability. Egan set the standard: objective reasonableness. Waller defined the defense: the genuine dispute doctrine. Brandt addressed the economics: attorney’s fees as compensatory damages. Jordan connected the regulatory framework to the common law: Fair Claims Regulation violations as evidence of bad faith. Bock extended liability to individual adjusters. McCoy required payment of undisputed amounts. Amadeo closed the loophole: manufactured disputes do not qualify as genuine. And Garvey established how causation determines coverage when multiple perils combine: the efficient proximate cause controls.

Together, they tell a story: the insurer has a duty to act in good faith (Gruenberg), measured by an objective standard (Egan), with a defense available for genuinely reasonable positions (Waller) — but that defense fails when the insurer manufactures the dispute (Amadeo) or fails to investigate (Jordan). When the insurer breaches this duty, the policyholder can recover extra-contractual damages including attorney’s fees (Brandt), and both the company and the individual adjuster may be liable (Bock). Throughout the process, the insurer must pay what it owes when it owes it (McCoy). And when the cause of loss itself is disputed, the efficient proximate cause doctrine (Garvey) ensures that coverage is determined by the predominant cause — not by whichever contributing cause the insurer finds most convenient to cite.

Part Two: California Insurance Appraisal Case Law

Insurance appraisal is a dispute resolution process embedded in virtually every property insurance policy in California, required by Insurance Code § 2071. When the insurer and policyholder agree that a loss is covered but cannot agree on the dollar amount, either party can invoke appraisal. The following cases define how appraisal works, what it can and cannot do, and what happens when the process goes wrong.

1. Kacha v. Allstate Insurance Co. (2006) 144 Cal.App.4th 1183

Kachais the foundational California case on the scope of appraisal. The Kachas’ home was damaged, and Allstate paid what they considered to be an inadequate amount. When the Kachas demanded appraisal, a dispute arose about what the appraisal panel was authorized to decide. Allstate argued that the panel could only determine the value of specific items it had already agreed were covered. The Kachas argued the panel could also decide whether certain damage was covered in the first place.

The Holding: The court drew a bright line: appraisal determines the amount of loss, not coverage. The appraisal panel has authority to determine what the covered damage is worth, but it does not have authority to decide whether particular damage is covered under the policy. Coverage questions — what caused the damage, whether an exclusion applies, whether the policy covers a particular type of loss — are for the courts or the parties to resolve, not the appraisal panel.

Significance: Kachaprotects both parties. It protects the insurer from having a coverage dispute decided by appraisers rather than a court. It protects the policyholder by ensuring that the insurer cannot use appraisal to sidestep its obligation to make a coverage determination — the insurer must take a position on coverage before the amount dispute goes to appraisal. In practice, Kacha means the principals (the insurer and the policyholder or their representative) must define the scope of what the appraisal panel will decide.

2. Devonwood Condominium Owners Association v. Farmers Insurance Exchange (2008) 167 Cal.App.4th 1498

Devonwood extended Kachaby addressing how the appraisal panel’s authority is defined and what role the umpire plays in the process. A condominium association suffered water damage, and the claim went to appraisal. Disputes arose about the scope of the panel’s authority and the umpire’s conduct.

The Holding: The court held that the appraisal panel has authority to determine the scope of damagethat falls within the appraisal — but only as to amount, consistent with Kacha. The court also emphasized that the umpire must be neutral and disinterested. An umpire who exhibits bias toward one party or who exceeds the panel’s authority undermines the integrity of the entire process. The court reinforced that appraisal is a quasi-arbitration proceeding subject to the protections of the California Arbitration Act (CCP § 1280 et seq.).

Significance: Devonwoodmatters for two reasons. First, it confirmed that within the scope of “amount,” the panel has real authority to evaluate the extent of damage — the insurer cannot artificially narrow the appraisal to only the items it has already agreed to pay. Second, by emphasizing umpire neutrality, Devonwoodestablished that the umpire’s role is fundamentally different from the appraisers’ roles. The appraisers are advocates for their respective sides; the umpire is the neutral tiebreaker. When the umpire acts as an advocate or favors one side, the award is compromised.

3. Lee v. California Capital Insurance Co.

Lee addressed what happens after an appraisal award is issued: can the losing party simply ignore it?

The Holding: The court held that appraisal awards carry a strong presumption of finality and are subject to confirmation and enforcement under the California Arbitration Act. A party seeking to vacate an appraisal award bears a heavy burden and must establish one of the narrow grounds set forth in CCP § 1286.2: corruption, fraud, or other undue means; partiality of the umpire; misconduct of the panel that substantially prejudiced a party’s rights; the panel exceeding its powers; or the panel’s refusal to hear material evidence.

Significance: Leegives appraisal awards real teeth. Without enforceability, appraisal would be an advisory process that either party could disregard. By applying the arbitration framework — including the strong presumption in favor of the award and the narrow grounds for vacation — Lee ensures that once the appraisal panel has spoken, the award is binding absent extraordinary circumstances. This also means that the process mustbe conducted properly, because an award issued through a flawed process can be challenged under CCP § 1286.2. The finality principle cuts both ways: it protects the winning party from having the award relitigated, but it also means that procedural irregularities during the appraisal may be the only basis for challenging an unfavorable result.

4. Sharma v. USAA

Sharmafocused squarely on the umpire’s obligation to be neutral and disclose potential conflicts of interest.

The Holding: The court held that the umpire in an appraisal proceeding is subject to the disclosure requirements of CCP § 1281.9, which require a neutral arbitrator (or umpire) to disclose any grounds for disqualification, including financial interests, prior relationships with the parties, and any other circumstances that could create an appearance of partiality. Failure to make required disclosures is itself a ground for vacating the award.

Significance: Sharma matters enormously in practice because the insurance appraisal world is small. Umpires who serve regularly may have repeated relationships with insurers, insurer-appointed appraisers, or law firms that represent carriers. Sharmarequires these relationships to be disclosed before the appraisal begins. If the umpire has been appointed by the same insurer in ten prior appraisals, or if the umpire has a financial relationship with the insurer’s appraiser, that must be disclosed. The disclosure obligation protects the integrity of the process by ensuring that both sides have the information they need to evaluate the umpire’s neutrality. When the umpire fails to disclose, the resulting award is vulnerable to vacation — even if the award itself was substantively reasonable.

5. Lambert v. Carneghi (2008) 158 Cal.App.4th 1120

Lambert addressed a question that causes confusion in nearly every appraisal: what role do the party appraisers play? Are they supposed to be neutral, or are they advocates?

The Holding: The court held that party appraisers are advocates, not neutrals. Each party’s appraiser is expected to represent that party’s position on the amount of loss, similar to how a party-appointed arbitrator in a tripartite arbitration panel represents that party’s perspective. The umpire alone is the neutral. This means that the insurer’s appraiser is expected to advocate for the insurer’s position, and the policyholder’s appraiser is expected to advocate for the policyholder’s position. Neither appraiser is required to be “disinterested” in the sense of being neutral — their role is inherently partisan.

Significance: Lambert is critical for public adjusters who serve as party appraisers. Before Lambert, insurers sometimes argued that a policyholder’s appraiser was “biased” or “not disinterested” because the appraiser advocated strongly for the policyholder. Lambert rejected this argument. The appraiser is supposedto advocate. The neutrality requirement applies only to the umpire. This role clarity is essential: the policyholder’s appraiser fights for the policyholder’s number, the insurer’s appraiser fights for the insurer’s number, and the umpire decides where the truth lies. When everyone understands their role, the process works. When roles are confused — particularly when the umpire acts as an advocate rather than a neutral — the process breaks down.

6. Bansal v. Nationwide Mutual Insurance Co. (N.D. Cal. 2023) Case No. 23-cv-05527-LB

Holding:An insurer that participates in the appraisal process and pays the resulting award is not liable for bad faith — even if its initial estimate was far below the appraised value.

Facts:A refrigerator line leak damaged the Bansals’ home. Nationwide sent an out-of-state adjuster from Iowa (not California-licensed) who estimated approximately $11,000 in damages. The Bansals retained a public adjuster, and their contractor estimated approximately $140,000. When the parties could not agree, the dispute went to appraisal. The appraisal panel awarded approximately $68,000, and Nationwide paid the award. The Bansals then sued for bad faith, arguing that Nationwide’s initial lowball estimate and delay constituted unreasonable conduct.

The Court’s Reasoning:The federal district court granted summary judgment for Nationwide on all counts. The court held that because Nationwide participated in the appraisal process and paid the resulting award, no benefits were “unreasonably withheld.” The initial disagreement over the amount of loss was precisely the type of dispute the appraisal clause was designed to resolve. The court also rejected the bad faith claim on ALE and food costs because the Bansals had not submitted the required documentation (receipts for additional living expenses) as required by the policy’s duties after loss provisions.

Why It Matters: Bansalis the counter-narrative to the general principle that bad faith survives appraisal. It demonstrates that when an insurer cooperates with the appraisal process and pays the award, courts may view the initial lowball as a legitimate dispute rather than bad faith conduct. The practical lesson for policyholders is twofold: first, document everything — the Bansals lost their ALE claim because they lacked receipts; second, understand that appraisal can insulate an insurer from bad faith liability for pre-appraisal conduct. If you intend to pursue bad faith in addition to the amount dispute, you may need to preserve your bad faith theory before agreeing to appraisal.

How the Appraisal Cases Interrelate: Six Core Principles

The appraisal cases discussed above establish a coherent framework built on six core principles. Understanding how they fit together is more important than memorizing any single holding.

1. Scope (Kacha): Appraisal determines the amount of loss, not coverage. The principals — the insurer and the policyholder (or their representative) — define the scope of what the panel will decide. Coverage questions are for the courts.
2. Process (Devonwood): Within the scope defined by the principals, the panel has real authority to evaluate the extent and value of damage. The insurer cannot artificially narrow the appraisal, and the process is subject to the protections of the California Arbitration Act.
3. Finality (Lee):Appraisal awards carry a strong presumption of finality. Once issued, an award can only be vacated on the narrow grounds set forth in CCP § 1286.2. This makes the process critically important, because a flawed process may be the only basis for challenging an unfavorable result.
4. Neutrality (Sharma):The umpire must be neutral and must disclose all potential conflicts of interest under CCP § 1281.9. Failure to disclose is itself a ground for vacating the award, regardless of whether the undisclosed conflict actually affected the outcome.
5. Role Clarity (Lambert):Party appraisers are advocates; the umpire is the neutral. Each participant has a defined role, and the process works only when everyone stays in their lane. A policyholder’s appraiser who advocates vigorously is doing their job. An umpire who advocates for one side is violating theirs.
6. Strategic Consequence (Bansal): Appraisal resolves the amount dispute, but it can also extinguish bad faith claims. An insurer that cooperates with appraisal and pays the award may be insulated from bad faith liability for pre-appraisal conduct. Policyholders must weigh the strategic tradeoff before invoking appraisal.

These six principles are mutually reinforcing. Kacha defines what the panel can decide (amount, not coverage). Devonwood ensures the panel has real authority within that scope. Lee makes the result binding. Sharma ensures the neutral is truly neutral. Lambert ensures that everyone understands their role. And Bansalreminds us that appraisal has strategic consequences beyond the amount — it can foreclose other remedies. When all six principles are respected and understood, appraisal works as intended: a fair, efficient process for resolving amount disputes without litigation. When any principle is violated or ignored, the process is compromised — and the resulting award may be unenforceable, or the policyholder may have given up more than they realized.

Related Resources

• Bad Faith Insurance Practices — A detailed guide to recognizing and documenting bad faith conduct.
• Insurance Appraisal in California: The Complete Guide — How the appraisal process works from start to finish.
• How and When to Invoke Appraisal: A Practitioner’s Guide — Step-by-step guidance on demanding appraisal, panel roles, causation issues, and post-award remedies.
• California Fair Claims Settlement Practices Regulations — The regulatory framework that Jordan v. Allstate connected to common law bad faith.
• Biased Insurance Experts — How insurers manufacture disputes using friendly experts, and how Amadeo limits this tactic.
• Engineering Reports vs. Coverage Determinations — How the efficient proximate cause doctrine from Garvey v. State Farm applies when insurers use engineering reports to attribute damage to excluded causes.