In Ridley v. Guaranty National Ins. Co., 286 Mont. 325, 951 P.2d 987 (1997), the Montana Supreme Court ruled that when liability is reasonably clear, an insurer is obligated to advance payments for medical expenses until a settlement is reached. Ridley, 286 Mont. at 334. In Ridley, the insurer's adjuster determined that the insured was 90% at fault for a car accident injuring the plaintiff. Ridley, 286 Mont. at 328. However, the insurer denied advance payments, contesting that the severity of the plaintiff's claims could not be attributed to the accident and that a final settlement needed to be reached before payments were made. Id. The Montana Supreme Court analyzed 33-18-201 (6) & (13), MCA, and determined that an insurer had an obligation to advance medical payments but only when liability was reasonably clear. Id. at 334.