Already have an account? Sign in instead.
You stay signed in for 30 days on this browser.
Continue with Google Continue with MicrosoftNo account yet? Create a free one.
We sent a six-digit code.
It expires in ten minutes, works once, and only in this browser. Five wrong tries void it. Send another code.
Your account is live and the Cloudflare checks are off for this browser.
13 Washington opinions name it 2 courts 1974–2025 3 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Tran v. State Farm Fire & Casualty Co.green2 sentences2025For example, in Tran, 136 Wn.2d at 217-19 , the policyholder, whose business was burglarized, refused to produce financial records related to his claim, in violation of the policy’s cooperation clause; the court held that as a result, the insurer was actually prejudiced because it was prevented from determining the validity of his claim. 2021“An insured’s breach of a cooperation clause releases the insurer from its responsibilities if the insurer was actually prejudiced by the insured’s breach.” Tran, 136 Wn.2d at 228 . | 1 | 5 |
Canron, Inc. v. Federal Insurancegreen1 sentence2025Canron, Inc. v. Federal Insurance Co., involved a notice clause that required the policyholder to give the insurer notice of any unanticipated “occurrence[s]” resulting in damage; the court held that the insurer was not actually prejudiced because it identified only “possible detriments” resulting from the policyholder’s year-long delay in notifying the insurer of potential liability for contamination of soil and groundwater. 82 Wn. | 1 | 1 |
Staples v. Allstate Insurancegreen1 sentence2014The Supreme Court held that "the insurer [must] demonstrate that it was prejudiced by the insured's actions before the cooperation clause will be considered breached so as to relieve the insurer from its obligations under the policy." Salzberg, 85 Wn.2d at 376 ; accord Staples, 176 Wn.2d at 417-18 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Oregon Automobile Insurance v. Salzberg
green
2 sentences2014The Supreme Court held that "the insurer [must] demonstrate that it was prejudiced by the insured's actions before the cooperation clause will be considered breached so as to relieve the insurer from its obligations under the policy." Salzberg, 85 Wn.2d at 376 ; accord Staples, 176 Wn.2d at 417-18 . 1994Co. v. Salzburg, 85 Wn.2d 372, 377 , 535 P.2d 816 (1975), we held that an insured's noncompliance with a cooperation clause releases the insurer from its responsibilities " only if the insurer was actually prejudiced by the insured's actions or conduct." The actual prejudice requirement has also been applied with regard to notice provisions. | 4 | 1978–2014 |
Tran v. State Farm Fire and Cas. Co.
green
2 sentences2019Tran, 136 Wash.2d at 231 , 961 P.2d 358 ("Tran's refusal to submit the requested financial information, an act which breached the cooperation clause and impeded State Farm's ability to investigate the claim, caused prejudice."); Pilgrim, 89 Wash. App. at 725 , 950 P.2d 479 ("The Pilgrims' refusal to disclose relevant financial information prejudiced State Farm as a matter of law."). 2001Co., 136 Wn.2d 214, 228 , 961 P.2d 358 (1998). | 3 | 2001–2019 |
Eakle v. Hayes
green
2 sentences1975Co., 90 Wash. 687 , 156 P. 861 (1916); Eakle v. Hayes, 185 Wash. 520 , 55 P.2d 1072 (1936) 1 *376 The Court of Appeals and the trial court relied upon this latter grouping of cases in ruling as a matter of law that Salzberg breached the cooperation clause, thereby releasing respondent Oregon Automobile Insurance Company from any liability and its duty to defend Salzberg irrespective of whether the company suffered prejudice. 1975Co., 90 Wash. 687 , 156 P. 861 (1916); Eakle v. Hayes, 185 Wash. 520 , 55 P.2d 1072 (1936) 1 *376 The Court of Appeals and the trial court relied upon this latter grouping of cases in ruling as a matter of law that Salzberg breached the cooperation clause, thereby releasing respondent Oregon Automobile Insurance Company from any liability and its duty to defend Salzberg irrespective of whether the company suffered prejudice. | 2 | 1974–1975 |
United Services Automobile Ass'n v. Morris
green
2 sentences2024The insurer waives the right to condition settlement on its consent when it defends under a reservation of rights, id., refuses to defend, Evans, 40 Wn.2d at 628 , or refuses in bad faith to settle a claim, Besel, 146 Wn.2d at 736 . 2024Morris explains the background principle that, traditionally, the cooperation clause in an insurance policy forbids an insured from settling without 21 No. 85400-3-I/22 the insurer’s consent, but this will govern “only claims for which the insurer unconditionally assumes liability under the policy.” 154 Ariz. at 119 . | 1 | 2024–2024 |
Evans v. Continental Casualty Co.
green
1 sentence2024The insurer waives the right to condition settlement on its consent when it defends under a reservation of rights, id., refuses to defend, Evans, 40 Wn.2d at 628 , or refuses in bad faith to settle a claim, Besel, 146 Wn.2d at 736 . | 1 | 2024–2024 |
Besel v. Viking Insurance
green
1 sentence2024The insurer waives the right to condition settlement on its consent when it defends under a reservation of rights, id., refuses to defend, Evans, 40 Wn.2d at 628 , or refuses in bad faith to settle a claim, Besel, 146 Wn.2d at 736 . | 1 | 2024–2024 |
Pilgrim v. State Farm Fire & Casualty Insurance
green
1 sentence2019Tran, 136 Wash.2d at 231 , 961 P.2d 358 ("Tran's refusal to submit the requested financial information, an act which breached the cooperation clause and impeded State Farm's ability to investigate the claim, caused prejudice."); Pilgrim, 89 Wash. App. at 725 , 950 P.2d 479 ("The Pilgrims' refusal to disclose relevant financial information prejudiced State Farm as a matter of law."). | 1 | 2019–2019 |
Pilgrim v. State Farm Fire & Cas. Ins. Co.
green
1 sentence2019Tran, 136 Wash.2d at 231 , 961 P.2d 358 ("Tran's refusal to submit the requested financial information, an act which breached the cooperation clause and impeded State Farm's ability to investigate the claim, caused prejudice."); Pilgrim, 89 Wash. App. at 725 , 950 P.2d 479 ("The Pilgrims' refusal to disclose relevant financial information prejudiced State Farm as a matter of law."). | 1 | 2019–2019 |
Shafer v. United States Casualty Co.
green
2 sentences1975Co., 90 Wash. 687 , 156 P. 861 (1916); Eakle v. Hayes, 185 Wash. 520 , 55 P.2d 1072 (1936) 1 *376 The Court of Appeals and the trial court relied upon this latter grouping of cases in ruling as a matter of law that Salzberg breached the cooperation clause, thereby releasing respondent Oregon Automobile Insurance Company from any liability and its duty to defend Salzberg irrespective of whether the company suffered prejudice. 1975Co., 90 Wash. 687 , 156 P. 861 (1916); Eakle v. Hayes, 185 Wash. 520 , 55 P.2d 1072 (1936) 1 *376 The Court of Appeals and the trial court relied upon this latter grouping of cases in ruling as a matter of law that Salzberg breached the cooperation clause, thereby releasing respondent Oregon Automobile Insurance Company from any liability and its duty to defend Salzberg irrespective of whether the company suffered prejudice. | 1 | 1975–1975 |
General Acc. Fire & Life Assur. Corp. v. Rinnert
green
1 sentence1974General Accident Fire & Life Assurance Corp. v. Rinnert, 170 F.2d 440 (5th Cir. 1948); Medico v. Employers’ Liab. | 1 | 1974–1974 |
Van Dyke v. White
green
2 sentences1974Van Dyke v. White, 55 Wn.2d 601 , 349 P.2d 430 (1960). 1974Van Dyke v. White, 55 Wn.2d 601 , 349 P.2d 430 (1960). | 1 | 1974–1974 |
Robert J. Connell v. Indiana Insurance Company, A/K/A Consolidated Insurance Company
neutral
1 sentence1974Co., 334 F.2d 993 (4th Cir. 1964); State Farm Mut. | 1 | 1974–1974 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.