In Stewart v. Estate of Bohnert (1980) 101 Cal. App. 3d 978, an insurance company appeared on behalf of a decedent's estate sued under former section 721, the predecessor statute to section 550. It moved for summary judgment "premised on the theory that the insurance policy contained an exclusion which precluded coverage under the facts as alleged by appellant." ( Id. at p. 984.) The trial court found the exclusion applied, granted the motion and entered judgment against the estate. ( Id. at p. 983.) The Court of Appeal affirmed, holding that "since recovery against the estate . . . is limited to the available insurance coverage under Probate Code section former 721, it would be futile to determine the question of liability in the abstract, before determining whether the policy covers such liability. The very quintessence of a summary judgment motion is to avoid the delay and expense of needless trials. In light of this purpose, it was clearly proper to allow the determination of insurance coverage before the determination of liability." ( Id. at p. 991.)