In Williams v. GEICO Casualty Co., the supreme court held that an insurer has a duty to not seek settlements that do not release all insureds. In 2000, Landt, an insured driver, ran over a man lying on the road. Dushkin was a passenger in the truck at the time. GEICO offered to settle with the decedent’s estate for the full policy limit of $50,000 in exchange for the release of liability for both Landt and Dushkin. When a settlement agreement could not be reached, GEICO filed for declaratory judgment. On appeal, the Shapsnikoffs argued that GEICO had a duty to offer or accept a settlement releasing Landt from liability even if so doing would leave Dushkin still liable. The supreme court affirmed the lower court’s decision, reasoning that Dushkin may have been an insured under a theory presented by the Shapsnikoffs. Thus, GEICO incurred a duty of good faith and fair dealings to Dushkin when they agreed to defend him. The court further reasoned that this meant GEICO had a duty not to seek settlements that did not release both Landt and Dushkin because bad faith claims could result otherwise. Affirming the lower court’s decision, the supreme court held that an insurer has a duty not seek settlements that do not release all insureds.