Law360, New York (November 4, 2015, 10:47 AM EST) -- The California Court of Appeal for the Fourth District, Division Two, in 21st Century Insurance Co. v. Superior Court (Tapia), 240 Cal.App.4th 322, 192 Cal.Rptr.3d 322 (No. E062244, Sept. 10, 2015), recently confirmed some of the important protections afforded to defending insurers against stipulated judgments and leaves little doubt that, under California law, policyholders may not "set up" a defending insurer for bad faith by entering into stipulated judgment in excess of limits without its insurer's consent. While this bedrock principle of California insurance law was firmly addressed and established in the Hamilton v. Maryland Casualty Co.[1] and Safeco Insurance Co. v. Superior Court[2] decisions, the court in 21st Century has limited the application of other appellate decisions that have been relied on by claimants and policyholders seeking to circumvent the Hamilton rule against bad faith actions premised on such stipulated judgments without a trial on damages....