California, United States of America
The following excerpt is from Callison v. Liberty Mut. Fire Ins. Co., G050633 (Cal. App. 2015):
Plaintiffs first argue their purported cause of action for "bad faith" is not an action "on the policy" and therefore the one-year limitation does not apply. Plaintiffs are wrong. In Cobb v. Ironwood Country Club (2015) 233 Cal.App.4th 960, we recently recognized "The covenant operates '"as a supplement to the express contractual covenants, to prevent a contracting party from engaging in conduct which (while not technically transgressing the express covenants) frustrates the other party's rights to the benefits of the contract."'" (Id. at p. 966.)
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