California, United States of America
The following excerpt is from Pikover v. Liberty Mut. Fire Ins. Co., B283206 (Cal. App. 2019):
Causes of action for bad faith denial of insurance coverage necessarily allege wrongdoing by the insurers occurring after the loss triggering coverage. Thus, while some types of insurer wrongdoing after the loss may not give rise to claims "under the policy," other allegations of bad faith misconduct, including, as here, charges that the insurer improperly denied coverage, do. (See, e.g., Velasquez v. Truck Ins. Exchange, supra, 1 Cal.App.4th at p. 722 ["Appellants claim that their action for wrongful cancellation of the policy and denial of their claim refers to events occurring before and after the loss and is not, therefore, an action on the policy. This assertion does not withstand close scrutiny"].)
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