Mealey's (February 6, 2018, 11:33 AM EST) -- SEATTLE — An insurer’s denial of defense, unsupported by evidence from a complaint against an insured, was a breach of its duty to defend, a Washington federal judge ruled Feb. 5, also finding that the insurer acted in bad faith despite its “later change of heart” (2FL Enterprises LLC v. Houston Specialty Insurance Co., No. 17-676, W.D. Wash., 2018 U.S. Dist. LEXIS 18605)....