RLI Insurance Co. v. CNA Casualty of Cal. (2006) 141 Cal.App.4th 75

RLI held that an excess insurer cannot sue a primary carrier in subrogation for bad-faith refusal to settle, where the underlying claim was not tried and the insured suffered no excess judgment.  Laurie persuaded Division 2 of the Second District to reject Division 1’s contrary precedent.