In Reid v. Mercury Insurance Company, No. B241154, --- Cal.Rptr.3d ----, 2013 WL 5517979 (Cal. App. 2 Dist. Oct. 7, 2013), the California Court of Appeals, Second Appellate District, held that, under California law, an insurer has no duty to initiate settlement negotiations or offer policy limits in the absence of a settlement demand from a third party claimant or some other evidence showing "an opportunity to settle" that the insurer ignored – even where the insured’s liability is clear.