Golden Gate University Law Review


This Note will analyze the reasoning utilized by the Moradi-Shalal court in overruling Royal Globe and also analyze its concomitant effects upon the rights of third party claimants. Third party claimants' alternatives to a Royal Globe action will then be considered, such as third party actions by assignment from the insured, and third party private causes of action against insurers pursuant to California Business & Professions Code Section 17200 et seq.

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