Recently, the Mississippi Supreme Court adopted a broad interpretation of the "volunteer defense" to claims asserting equitable subrogation and indemnity. The Court in Colony Ins. Co. v. First Specialty Ins. Corp., 262 So.3d 1128 (Miss. 2019) held that when an insurance company settles a claim while it was simultaneously contesting whether it had an insured relationship with the putative insured defendant, the settling liability insurer acted as a volunteer in settling the claim and, therefore, could not bring an equitable subrogation against other insurance companies.