Cal.Sup.Ct.
S178542

The California Supreme Court affirmed a court of appeal judgment. The court held that Moradi-Shalal v. Fireman’s Fund Ins. Companies (1988) 46 Cal.3d 287 does not preclude a first party action against an insurer under the Unfair Competition Law, even when the insurer’s conduct violates the Unfair Insurance Practices Act, so long as the action is based on grounds independent of the insurer’s alleged unfair practices.