The California Supreme Court recently issued a significant decision regarding the applicability of that state’s Unfair Competition Law (UCL) to the insurance industry, allowing certain types of such claims to be brought against insurers, potentially expanding insurers’ extra-contractual liability in that jurisdiction. On August 1, 2013, in Zhang v. The Superior Court Of San Bernardino

In Florida, bad-faith actions against insurers pursuant to Section 624.155 cannot be brought until (1) the insured files a civil remedy notice (CRN) accepted by Florida’s Department of Financial Services; and (2) the underlying breach of contract lawsuit is “resolved in the insured’s favor.” See Blanchard v. State Farm Mut. Ins. Co., 575 So.