Can an insurer be held liable for attorney's fees incurred as a result of bad faith and fair dealing?

A covenant of good faith and fair dealing implied in insurance contracts is often relied on by California courts to hold insurers liable for attorney's fees incurred as a result of bad-faith denials of payment. Brandt v. Superior Court, 37 Cal.3d 813, 817, 210 Cal.Rptr. 211, 693 P.2d 796 (1985). INA argues the implied covenant of good faith and fair dealing places a corresponding duty on the insured, and an insured who breaches the duty of good faith and fair dealing therefore may be held liable

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