The following excerpt is from Morrell Const., Inc. v. Home Ins. Co., 920 F.2d 576 (9th Cir. 1990):
Courts which have directly addressed the issue have split as well. Cf. Alt v. American Family Mut. Ins. Co., 71 Wis.2d 340, 237 N.W.2d 706, 713 (1976) (duty on insurer to initiate settlement negotiations), with Miller v. Kronk, 35 Ohio App.3d 103, 519 N.E.2d 856, 858 (1987) (no duty on insurer to initiate settlement negotiations). The Alt court explained:
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