Under Nevada law, an insurer is required to provide independent counsel of the insured choosing when a conflict of interest arises between the insured and the insurer. A reservation of rights fails to create a per se conflict of interest. Instead, the courts must analyze on a case-by-case basis whether an actual conflict exists. Only if an actual conflict exists, must an insurer be obligated to provide the insured with independent counsel.
Matteoni, Kristen, "State Farm Mut. Auto. Ins. Co. v. Hansen, 131 Nev. Adv. Op. 74 (Sept. 24, 2015)" (2015). Nevada Supreme Court Summaries. 903.