In a case decided under Pennsylvania law, it was held that there was no First-Party Bad Faith under a commercial property insurance policy. The carrier's delay in paying the claim was attributable to the claim's uncertain value, and a need to investigate further. The case involved Pennsylvania's bad faith statute, 42 Pa. Cons. Stat. § 8371. Great Lakes Reins. (UK) PLC v. Stephens Garden Creations, Inc., 119 F. Supp. 3d 297, 306 (E.D. Pa. 2015).
Please Read The Disclaimer. ©2016 by Dennis J. Wall, author of Litigation and Prevention of Insurer Bad Faith (3d ed. Thomson Reuters West in 2 Volumes, with Supplements). See in particular § 9:6 in Volume 2 which addresses the issues which were addressed in the Great Lakes case, "The Question of Bad Faith -- Timely Investigation and Evaluation Before and After The First-Party Insurer is Sued for Bad Faith." All rights reserved.