Can a defendant be held liable for intentional infliction of emotional distress for delaying or denying an insurance claim?

In Coleman v. Republic Indemnity Ins. Co. (2005) 132 Cal.App.4th 403 the plaintiffs alleged the defendant had advised a claimant not to hire a lawyer and misrepresented the statute of limitations within which to file a claim, both statutory violations. The court ruled this was not a sufficient allegation to support a cause of action for intentional infliction of emotional distress. (Id. at p. 417.) In so doing, it cited a line of California cases that hold neither delay nor outright denial of insurance claims is outrageous enough to support an intentional infliction of emotional distress cause of action. (Ibid.)