loss as the result of allegedly mishandled claims.”); Charleston Dry Cleaners & Laundry, Inc. v. Zurich Am. Ins. Co., 355 S.C. 614, 586 S.E.2d 586, 588-89 (2003) (We decline to recognize a general duty of due care from an independent insurance adjuster or insurance adjusting company to the insured, and thereby align South Carolina with the majority rule on this issue.”); Meineke v. GAB Bus. Servs., Inc., 195 Ariz. 564, 991 P.2d 267, 270-71 (Ct.App.1999) (same); Sanchez v. Lindsey Morden Claims Servs., Inc., 72 Cal.App.4th 249, 84 Cal.Rptr.2d 799, 803 (1999) (same); King v. Nat’l Sec. Fire & Cas. Co., 656 So.2d 1338, 1340 (Fla.Dist.Ct. App.1995) (same). Only a sparse minority of courts have held otherwise.. See, e.g., Morvay v. Hanover Ins. Cos., 127 N.H. 723, 506 A.2d 333, 335 (1986) (<HOLDING>); Brown, 58 P.3d at 223 (same); Cont’l Ins. Co.
holding insurance agent has no duty to advise insured of amount of insurance necessary to cover all potential losses holding that where the insurer retains an attorney to represent the insured pursuant to an insurance policy the attorney acts in the capacity of an independent contractor for the insured holding that an insurance policy providing that the insurance company would pay all reasonable expenses incurred by the insured at our request emphasis omitted did not establish an agreement that the insurer would cover attorney fees and costs to the insured in a declaratory action holding that independent insurance investigators owe a duty of care to the insured as well as to the insurer to conduct a fair and reasonable investigation of an insurance claim because insured could be harmed financially if investigations were performed negligently holding that an agent breaches its duty to use reasonable care and diligence in procuring insurance when it fails to provide an insurance policy that covers the contents of the insureds business as the insured had requested