A recent California Court of Appeal case, Howard v. American National Fire Insurance Co., 187 Cal. App. 4th 498 (2010), addresses a question that all insurance litigators will find of particular interest: whether an insurer can breach its duty to settle by rejecting a settlement offer that is within the total available limits of all the insurers' policies, but which exceeds the limits of its own individual policy.  In the first clear statement of California law on this issue, the First Appellate District ruled that the answer is "yes."

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