Brehm v. 21st Century Ins. Co. (2008) 166 Cal.App.4th 1225, was concerned with an insured who claimed that her insurer had unreasonably investigated her uninsured motorist claim. The insurer had relied on its own medical examination of the insured plaintiff, which had concluded that she presented only "'subjective complaints with no objective evidence of injury or problem.'" (Id. at p. 1239.) In her complaint, Brehm alleged that the doctor's "examination was a sham; that he was retained by the insurer with the intention he prepare a report that falsely minimized the seriousness of Brehm's injury precisely so that the insurer could argue there was a 'genuine dispute' as to the value of the claim; and that the doctor did exactly as he was expected to do." (Ibid.) The insurer demurred on the basis that its settlement offer to Brehm was objectively reasonable as a matter of law, as it was based on its doctor's evaluation, and the trial court agreed. The appellate court reversed, in part, on the basis that the insurer could not prevail without establishing both objectively reasonable conduct and good faith subjective intent. (Brehm, supra, 166 Cal.App.4th at p. 1238.) Thus, the availability of the genuine dispute doctrine was, in light of the allegations in Brehm's complaint, an issue that could not be resolved on demurrer. (Id. at p. 1240.)