What is the test for making a settlement offer in a personal injury case?

Of course, I do not wish to imply that a court may or should require any party to make a settlement offer. There are, indeed, cases which should not be settled. They are rare, but they do exist. Morals and principles sometimes preclude settlement. Obviously, refusal to make an offer is not in and of itself synonymous with failure to participate in settlement discussions in good faith. However, refusal even to attend a settlement conference to discuss a "no settlement" position with the court may constitute bad faith. (Cf. City of El Monte v. Takei (1984) 158 Cal.App.3d 244, 249-250, 204 Cal.Rptr. 559.)