In Safeco Insurance Co v. Parks, __ Cal. Rptr. 3d __, 2009 WL 190037 (filed Jan. 28, 2009, Cal. Ct. App.), a California appellate court held that an insurer’s duty to investigate may extend beyond the facts and coverage theories in the insured’s claim.  The court called the facts "unusual" but found, here, the insurer should have determined whether it issued any other policy that might apply to the policyholder's claim.

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