Arizona Supreme Court

Apollo Education v. National Union Fire Insurance

February 17, 2021

Summary

The court answered a certified question concerning an insurer's refusal to consent to a settlement under a liability policy without a duty to defend. It held that reasonableness must be assessed from the insurer's perspective, while requiring the insurer to independently investigate, value, and give full and fair consideration to the settlement. The insurer need not approve a settlement merely because the insured considers it reasonable.