The succinct phrase "dependent counsel" describes the counterpart to "independent counsel." The difference between dependent counsel and independent counsel is simple and can be succinctly stated. Dependent counsel represents the interests of the insurer, while independent counsel does not. Dependent counsel "has two clients." Dependent counsel must comply with Rules of Professional Conduct, Rule 3-310 (joint representation) while independent counsel does not. Thus, dependent counsel has ethical considerations that independent counsel does not.
The leading California reported opinion imposing a duty upon dependent counsel to behave ethically is San Diego Navy Fed. Credit Union v. Cumis Ins. Society, Inc. (1984) 162 Cal.App.3d 358, 364 (Cumis). It describes many ethical pitfalls for dependent counsel.
 See, Article: Duty to Comply with Rule 3-310.
 Purdy v. Pacific Automobile Ins. Co.(1984) 157 Cal.App.3d 59, 77.
 Id. at 374 (citations omitted).
 Id. at 375 (citations omitted).
 Haven, supra, 32 Cal.App.4th at 83-84 (citations omitted).
 Id. at 87 (citations and ellipses omitted).
 Id. at 90-91 (ellipsis omitted).