Washington State leads the way in determining a duty to defend, and thus in determining whether denial of a defense was wrongful. See, e.g., United Serv's Auto. Ass'n v. Speed, 317 P.3d 532, ¶ 15, at 538 (Wash. Ct. App. Div. 2 January 28, 2014) (where coverage is conceivable for the claim(s)s pled in the complaint against the insured, there is a duty to defend; actual coverage is required for the duty to settle or indemnify); Grange Ins. Ass'n v. Roberts, 177 Wash. App. 1021, 2013 WL 5806663 *4 (Wash. Ct. App. Div. 1 October 28, 2013)(same).
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