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Supreme Court of California

Zhang v. Superior Court (California Capital Insurance Company), S178542

Although Moradi-Shalal v. Fireman’s Fund Ins. Companies bars private actions for unfair insurance practices under the Unfair Insurance Practices Act (UIPA), it does not preclude first party actions brought under the Unfair Competition Law (UCL) based on grounds independent from Insurance Code section 790.03, even when the insurer's conduct also violates section 790.03, and here plaintiff alleges causes of action for false advertising and insurance bad faith, both of which provide grounds for a UCL claim independent from the UIPA, so allowing her also to sue under the UCL does no harm to the rule established in Moradi-Shalal.

Appellate Information

  • Decided 08/01/2013
  • Published 08/01/2013




  • Supreme Court of California


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