SACRAMENTO, Calif. - An insurer had no duty to name its insured as a co-plaintiff in seeking recovery from the manufacturer of a defective chair massager, a California appeals panel affirmed April 30, further finding that the insured's negligence claim against the insurer constituted a nonviable cause of action (James Sedlar v. USAA Casualty Insurance Company Inc., No. C066089, Calif. App., 3rd Dist.; 2012 Cal. App. Unpub. LEXIS 3226).