Nevada Recognizes Excess Carrier Bad-Faith Claims

The Nevada Supreme Court held in North River Insurance Company v. James River Insurance Company that an excess insurer may pursue a primary insurer through equitable subrogation for an alleged bad-faith failure to settle. North River had funded the $4 million excess portion of a settlement after James River allegedly refused reasonable settlement opportunities within its $1 million limits. The court said the remedy exists even when the case settles within the combined limits of the policies.