California, United States of America
The following excerpt is from Anton v. Barbich Hooper King Dill Hoffman Accountancy Corp., F073713, F074644 (Cal. App. 2020):
10. The threat of a bad faith lawsuit against an insurance company, in the context of cases like Parichan, are based on a claim of common law bad faith arising from an insurance company's breach of the implied covenant of good faith and fair dealing, and may expose the insurance company to tort damages, including punitive damages. (Jordan v. Allstate Ins. Co. (2007) 148 Cal.App.4th 1062, 1073.)
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