In a highly-anticipated decision regarding an insurer's rights against an insured's independent counsel, the California Supreme Court has ruled that an insurer may sue independent counsel for reimbursement of excessive defense costs if those costs were paid involuntarily pursuant to a trial-court order that expressly permitted the insurer to "recover payments of excessive fees." Hartford Cas. Ins. Co. v. J.R. Marketing, LLC, ___ Cal. 4th ___ (Aug. 10, 2015).