SAN FRANCISCO - An insurer had a duty to defend underlying lawsuits alleging negligent construction work on a dam, not engineering or supervisory services, caused the alleged downstream-property damage, a California appeals panel held March 13, reversing a trial court's entry of a directed verdict in favor of the insurer on breach of contract and bad faith claims (North Counties Engineering Inc., et al. v. State Farm General Insurance Co., No. A133713, Calif. App., 1st Dist., Div. 2; 2014 Cal. App. LEXIS 235).