Robert C. Clifford discusses the issues raised by the California Supreme Court's decision in Wilson v. 21st Century Ins. Co., 2007 Cal. LEXIS 13314 (Cal. 2007) in this commentary. Although this case involved an insured's claim for underinsurance benefits, the implications of the holding go beyond underinsurance coverage and must be considered in all first party coverage situations. The California Supreme Court held that before an insurer denies a first party claim, the insurer must thoroughly investigate the facts and undertake a fair evaluation of its insured's claim.