National Union Fire Insurance Co. Of Pittsburgh, Pennsylvania v. Cna Insurance Companies and Columbia Casualty Company

EMILIO M. GARZA, Circuit Judge:

National Union Fire Insurance Company (“National Union”), an upper-level excess insurance carrier, brought an action against a lower-level excess insurance carrier, Columbia Casualty Company (“Columbia”), claiming that Columbia had breached either a direct or indirect duty to National Union to settle litigation brought against the mutual insured, Ariens Company (“Ariens”). On appeal, we must determine whether the district court erred in granting summary judgment in favor of Columbia. Finding no error, we affirm.

I

The underlying facts are undisputed. Ar-iens…