California, United States of America
The following excerpt is from Mottola v. R. L. Kautz & Co., 199 Cal.App.3d 98, 244 Cal.Rptr. 737 (Cal. App. 1988):
[199 Cal.App.3d 109] Based on the foregoing we hold that an independent claims adjuster of a self-employed insurer is imbued with the same immunity from civil suit as his principal as long as the adjuster discloses his agency role and commits no intentional tort while investigating the claim in question. (But see Bayuk v. Edson (1965) 236 Cal.App.2d 309, 319-320, 46 Cal.Rptr. 49.)
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