SANTA ANA, Calif. - A California appeals panel on Oct. 1 held that an insurer has no duty to defend its nonprofit residential community association insured against an underlying lawsuit initially seeking injunctive relief but no compensatory damages, affirming a lower court's ruling in favor of the insurer (San Miguel Community Association, et al. v. State Farm General Insurance Co., No. G047738, Calif. App., 4th Dist., Div. 3).