In Philadelphia Indemnity Ins. Co. v. Montes-Harris, No. S130717, 2006 WL 3517847 ( Cal. Dec. 7, 2006), the California Supreme Court held that an excess liability insurer had no duty to investigate when a rental car agency examined a drivers license that was facially valid but had been suspended.

 

Alric Burke rented a car and presented a drivers license that appeared valid. The rental agent photocopied the license, and Burke signed the rental agreement. Burke also purchased excess liability insurance, which was offered by the rental agency.

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