STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, Appellant, vs. STEPHEN TANNER HANSEN, Respondent., 131 Nev. 743

Summary

HOLDINGS: [1]-Nevada law required an insurer to provide independent counsel for its insured when a conflict of interest arose between the insurer and the insured; when an insured and an insurer had opposing legal interests, Nevada law required insurers to fulfill their contractual duty to defend their insureds by allowing insureds to select their own independent counsel and paying for such representation; [2]-An insurer was only obligated to provide independent counsel when an insured's and the insurer's legal interests actually conflicted; a reservation of rights letter did not create a per se conflict of interest.