Does an insurance agent have a "special duty" to advise an insured that their policy limits are adequate to rebuild their home?

For example, in Free v. Republic Ins. Co. (1992) 8 Cal.App.4th 1726, the court found that a "special duty" may arise if the agent takes affirmative steps to expand his relationship with the insured. In Free, the defendant insurance company issued plaintiff a homeowners policy in 1979. That year and every succeeding year until 1989, plaintiff contacted his insurance agent and asked whether his coverage limits were adequate to rebuild his home; on each occasion, he was told they were. When plaintiff's home was completely destroyed by fire in 1989, however, plaintiff discovered that his policy limits were insufficient to replace his home. (Id. at p. 1729.) He sued his agent for negligence, asserting that the agent had a duty to provide him with accurate information and breached this duty by advising him that his coverage was adequate. (Ibid.) The court held that the plaintiff's claim stated a cause of action for negligence. It explained: "Clearly defendants were not required under the general duty of care they owed plaintiff to advise him regarding the sufficiency of his liability limits or the replacement value of his residence. [Citation.] Nonetheless, once they elected to respond to his inquiries, a special duty arose requiring them to use reasonable care." (Ibid.)