Mariscal v. Old Republic Life Ins. Co. (1996) 42 Cal.App.4th 1617 arose out of a first-party policy (for accidental death). After an auto accident, the insured, who had a history of heart disease, was taken to a hospital where he died. The treating doctor wrote on the proof of loss form that the cause of death was the auto accident, but the insurer denied the accidental death claim on the theory that the insured had died of a heart attack, without ever interviewing the treating doctor, anybody else involved in the accident, or even have its own doctor review certain records it did obtain. (See id. at pp. 1621-1622.)