Delos v. Farmers Group, Inc

In Delos v. Farmers Group, Inc. (1979) 93 Cal. App. 3d 642, the court noted that both Farmers Group and Farmers Insurance Exchange had conceded their fiduciary duties by failing to respond to requests for admissions. However, the court also declared that Farmers Group, as attorney-in-fact for the plaintiffs, "owed them a fiduciary duty in reference to insurance matters involving the Exchange." (Id. at p. 655.) In Delos, supra, the court deemed Farmers Group a fiduciary for purposes of all the Exchange's insurance business, because it was convinced that the Group exercised all the functions of an insurer, including control over claims processing. (Delos, 93 Cal. App. 3d at pp. 652-653, 655.)