Can an insurer be held liable in tort for breach of the implied covenant of good faith?

benefits due under the policy may be held liable in tort for breach of the implied covenant. [Citation.]' [Citation.]" (Maslo v. Ameriprise Auto & Home Ins. (2014) 227 Cal.App.4th 626, 633 (Maslo).)

"An insurer is said to act in 'bad faith' when it breaches its duty to deal 'fairly' and 'in good faith' with its insured. [Citation.] The term 'bad faith' does not connote 'positive misconduct of a malicious or immoral nature' [citation]; it simply means the insurer acted deliberately." (Major, supra, 169 Cal.App.4th at p. 1209.) "[A]n insured plaintiff need only show, for example, that the insurer unreasonably refused to pay benefits or failed to accept a reasonable settlement offer; there is no requirement to establish subjective bad faith. [Citations.]" (Bosetti v. United States Life Ins. Co. in City of New York (2009) 175 Cal.App.4th 1208, 1236 (Bosetti).)