In Choy v. Redland Ins. Co. (2002) 103 Cal.App.4th 789, a personal injury plaintiff filed suit against several defendants, only one of whom failed to settle. (Id. at pp. 792-794.) The nonsettling defendant filed chapter 7 bankruptcy proceedings before the underlying litigation was resolved. (Id. at p. 794.) The personal injury plaintiff filed a second state court action, this one against the nonsettling defendant's insurers and attorneys. (Id. at pp. 792-793.) The plaintiff stated causes of action for intentional infliction of emotional distress and abuse of process. (Id. at p. 795.) He asserted that the insurers had failed to settle his claim for policy limits, instead pushing the nonsettling defendant into bankruptcy, in bad faith. (Id. at pp. 793-795.) The plaintiff, "while recognizing the settled principle of law that a bankruptcy court has exclusive jurisdiction over claims for abuse of process which are asserted by or against a debtor in bankruptcy, argued that such rule had no application in a case, such as that one, where the claim was not asserted against the debtor, but rather against the debtor's insurer and attorneys." (Id. at p. 795.) The court rejected that assertion and held that the state court had no subject matter jurisdiction to hear the second state court lawsuit. (Id. at pp. 795, 801-802.) The court in Choy held that there were three reasons why the state court did not have subject matter jurisdiction. First, it stated that in order to address the plaintiff's assertions, the trial court would have to determine whether the bankruptcy proceedings had been initiated "in 'good faith' within the meaning of the Bankruptcy Code." (Id. at p. 801.) Second, it emphasized that "if a bad faith claim against the insurer defendants was one of the debtor's assets, it was for the bankruptcy trustee to pursue it. The plaintiff was free to file a claim in bankruptcy and have that claim approved or adjudicated . . . and, if such claim exceeded the relevant policy limits of the insurer defendants, to request that the trustee pursue a claim for an excess judgment against the insurer defendants." (Ibid.) Third, it noted that to permit the plaintiff to proceed in state court would be to allow the circumvention of the bar on direct bad faith actions by third party claimants against insurers. (Ibid.)