Does a seller have an insurable interest in the property after they have sold it?

Under Banerian v. O'Malley (1974) 42 Cal.App.3d 604, 116 Cal.Rptr. 919, a seller does not have an insurable interest in property after he or she sells it. Banerian was a legal malpractice case which required the court to determine whether the seller of certain property had an insurable interest in it. The case arose from an underlying suit for negligent misrepresentation by the seller in a real property transaction. The buyer sued for damages resulting from extensive land movement which took place two months after the policy terminated and more than a year after the seller sold the property. The court held the seller did not have an insurable interest in the property within the meaning of Insurance Code section 286 because the loss occurred at the time the property was damaged, which was after the policy had lapsed, and not at the time of the misrepresentations and sale, when the policy was in force. (Id. at p. 615, 116 Cal.Rptr. 919.)