What is a cause of action for breach of the implied covenant of good faith and fair dealing?

A cause of action for breach of the implied covenant of good faith and fair dealing is established when an insurer " 'fails to deal fairly and in good faith with its insured by refusing, without proper cause, to compensate its insured for a loss covered by the policy . . . .' " (Neal v. Farmers Ins. Exchange (1978) 21 Cal.3d 910, 920, quoting Gruenberg v. Aetna Ins. Co. (1973) 9 Cal.3d 566, 574.) "Among the most critical factors bearing on the insurer's good faith is the adequacy of its investigation of the claim. '[T]he covenant of good faith and fair dealing implied in all insurance agreements entails

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