California Codes

Cal. Insurance Code § 22 (2026)

✓ current as of May 2026
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Insurance is a contract whereby one undertakes to indemnify another against loss, damage, or liability arising from a contingent or unknown event.

Notes of Decisions
Cited in 60 cases (4 in the last 5 years), 1946–2025 · leading case: Cates Constr., Inc. v. Talbot Partners, 980 P.2d 407 (Cal. 1999).
Cates Constr., Inc. v. Talbot Partners, 980 P.2d 407 (Cal. 1999). · cites it 4× “) [11] *868 The Insurance Code defines "Insurance" to mean "a contract whereby one undertakes to indemnify another against loss, damage, or liability arising from a contingent or unknown event.”
Waller v. Truck Ins. Exch., Inc., 900 P.2d 619 (Cal. 1995). · cites it 2× “) Insurance typically is designed to protect against contingent or unknown risks of harm (Ins. Code, §§ 22, 250), not to protect against harm that is certain or expected.”
Catholic Mut. Relief Soc'y v. Superior Court, 165 P.3d 154 (Cal. 2007). · cites it 4× “) Before examining the controlling language of section 2017.210, it will be helpful to briefly consider some fundamental differences between liability insurance and reinsurance.”
Sweatman v. Dep't of Vets. Affairs, 18 P.3d 29 (Cal. 2001). · cites it 2× “) C Sweatman contends that the disability coverage under the Cal-Vet home protection plan constitutes insurance subject to the Insurance Code.”
Safeco Ins. of Am. v. Robert S., 28 P.3d 889 (Cal. 2001). · cites it 2× “GEORGE, C.J., WERDEGAR, J., and CHIN, J., concur.”
Montrose Chem. Corp. v. Admiral Ins., 897 P.2d 1 (Cal. 1995). · cites it 2× “I also agree that the statutory "loss-in-progress" rule (Ins. Code, §§ 22, 250) does not conclusively eliminate Admiral's duty to help defend the various contamination-injury suits against Montrose.”
Stonewall Ins. v. City of Palos Verdes Estates, 96 Cal. Daily Op. Serv. 4520 (Cal. Ct. App. 1996). · cites it 3× “Coverage is not eliminated by the “known loss” rule, sometimes called the “loss-in-progress” rule (Ins. Code, §§ 22 & 250). 8. Coverage is not eliminated by the policies’ “expected or intended” limitation.”
Reichert v. Gen. Ins. of Am., 442 P.2d 377 (Cal. 1968). · cites it 3× “The remaining question in the view I take of the matter is one with which the majority does not deal, namely, whether plaintiff may recover damages caused by bankruptcy which resulted from the wrongful conduct of insurers in failing to pay a fire loss.”
Armstrong World Indus., Inc. v. Aetna Cas. & Sur. Co., 96 Cal. Daily Op. Serv. 3058 (Cal. Ct. App. 1996). · cites it 2× “(Ins. Code, §§ 22, 250) The rule does not apply if the damage was unknown or contingent or the insured’s liability was uncertain at the time the policy was issued, even if the damage was inevitable.”
Broberg v. Guardian Life Ins. Co. of Am., 61 A.L.R. 6th 707 (Cal. Ct. App. 2009). · cites it 2× “) Insurance, in contrast, is defined by the Insurance Code as "a contract whereby one undertakes to indemnify another against loss, damage, *925 or liability arising from a contingent or unknown event.”
Wayne v. Staples, Inc., 2006 Cal. Daily Op. Serv. 92 (Cal. Ct. App. 2006). · cites it 2× “[3] Insurance Code section 22 defines insurance as "a contract whereby one undertakes to indemnify another against loss, damage, or liability arising from a contingent or unknown event.”
Metro. Life Ins. v. State Bd. of Equalization, 652 P.2d 426 (Cal. 1982). · cites it 2× “[1] After the State Board of Equalization (Board) rejected its claim, Metropolitan sued for a refund and obtained a judgment for the full amount requested.”
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