In California State Auto. Assn. Inter-Ins. Bureau v. Parichan, Renberg, Crossman & Harvey (2000) 84 Cal.App.4th 702 (CSAA), an insurance company sued the attorney who handled a car accident case for one of its insureds at the company's direction. (Id. at pp. 704-706.) The attorney acted in a dual capacity representing both the insurance company in providing transactional business advice concerning coverage and providing litigation services for the insured in the underlying litigation. (Id. at p. 711.) During the course of the litigation, the attorney failed to provide the insurance company with a critical report that would have allowed it to properly evaluate a policy limits settlement offer. (Id. at p. 708.) This failure exposed the insurance company to a bad faith lawsuit by its insured. (Ibid.) As a result, the company paid a settlement far in excess of its policy limits. (Ibid.) The defendant attorney in CSAA contended that the insurance company needed to show under the case-within-a-case methodology that it would have gotten a better result in the underlying litigation but for the negligence of its attorney in failing to provide the report. (Id. at pp. 709-710.) The appellate court rejected the application of the case- within-a-case approach in the context of transactional legal advice. (CSAA, supra, 84 Cal.App.4th at pp. 709-710.) The court conceded, "Our review of the abundant precedent in the legal malpractice arena indicates that the case-within-a-case methodology is not universally used to determination causation and damages. Although no bright line rule tells us when this methodology must be used, it is quite clear that, when the malpractice involves negligence in the prosecution or defense of a legal claim, the case-within-a-case method is appropriately employed." (Id. at p. 710.) The CSAA court continued, "However, in other contexts, most often involving business transactions, causation and damages may be more simply established under rules applicable to all negligence claims and the case-within-a-case procedure is not utilized." (CSAA, supra, 84 Cal.App.4th at p. 711.)