Julian v. Hartford Underwriters Insurance

Opinion

MORENO, J.

California Insurance Code section 5301 provides that “[a]n insurer is liable for a loss of which a peril insured against was the proximate cause, although a peril not contemplated by the contract may have been a remote cause of the loss; but he is not liable for a loss of which the peril insured against was only a remote cause.” We have construed section 530 as incorporating into California law the efficient proximate cause doctrine, an interpretive rule for first party insurance. (Sabella v. Wisler (1963) 59 Cal.2d 21, 31-33 [27 Cal.Rptr. 689, 377 P.2d 889] (Sabella).)…