California Court of Appeal June 22, 2006, B189637 (Safeco Ins. Co. of America v. Superior Ct.)

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Opinion

VOGEL, J.

We hold that in an action for equitable contribution by a settling insurer against a nonparticipating insurer, the settling insurer has met its burden of proof when it makes a prima facie showing of coverage under the nonparticipating insurer’s policy—the same showing of potential coverage necessary to trigger the nonparticipating insurer’s duty to defend—and that the