Lara
State Farm General Insurance Company v. Lara
Opinion
Opinion
INTRODUCTION
State Farm General Insurance Company (SFG) appeals from an order awarding attorney fees to intervenor Consumer Watchdog (CW), in a dispute over documents SFG designated as confidential in a rate hearing under
Proposition 103 (Ins. Code, § 1861.01 et seq.).1 After the administrative law judge (ALJ) denied SFG’s motion to seal, SFG sought writ relief from the superior court, which CW and the Insurance Commissioner successfully opposed. CW then moved for fees under section 1861.10, which provides for reasonable advocacy fees to a consumer representative that makes a substantial contribution to the adoption of an order. The court awarded CW’s requested fees, and SFG appealed. SFG contends the fee motion was untimely, and the fee award was inconsistent with the statutory requirements and an abuse of discretion. We reject these arguments and affirm.
FACTUAL AND PROCEDURAL BACKGROUND
A. Proposition 103 Proposition 103 was approved by voters in November 1988, and made numerous, fundamental changes to insurance regulation in California. (Calfarm Ins. Co. v. Deukmejian (1989) 48 Cal.3d 805, 812 (Calfarm).) Its stated purpose was “to protect consumers from arbitrary…