What is the current state of the law on covenant not to execute?

3 "[A]n insured breaches no duty to the insurance company when he [or she] assigns his [or her] rights against the company to the injured plaintiffs in return for a covenant not to execute." (Samson v. Transamerica Ins. Co. (1981) 30 Cal.3d 220, 240, 178 Cal.Rptr. 343, 636 P.2d 32.) "When the insurer 'exposes its policyholder to the sharp thrust of personal liability' by breaching its obligations, the insured 'need not indulge in financial masochism....' [Citation.]" (Id. at p. 241, 178 Cal.Rptr. 343, 636 P.2d 32.)