The Nevada Supreme Court recognized for the first time an insured's right to independent counsel. In State Farm Mutual Auto. Ins. Co. v. Hansen, the Court ruled that Nevada law requires an insurer to pay for independent counsel, chosen by the insured, when an ethical conflict of interest exists between the insurer and the insured. The Court recognized that Nevada, like California, is a dual-representation state where insurer-appointed counsel represents both the insurer and the insured.