Case Notes

See also notes at end of this chapter.

Request by intervenor-defendant for attorneys' fees and costs denied; even assuming intervenor-defendant, as a tort victim of an insured, may under some circumstances have a "legally protectable interest" in insured's policy, intervenor-defendant was neither "the policyholder, the beneficiary under a policy, [n]or the person who has acquired the rights of the policyholder or beneficiary under the policy". 939 F. Supp. 782.

Where self-insurer rent-a-car company not an "insurer" as defined in §431:10C-103, court erred in granting attorney's fees and costs under this section. 85 H. 243, 942 P.2d 507.

Cited: 73 H. 322, 832 P.2d 733.