The case of Idaho Trust Bank v. Bancinsure, Inc., 2014 WL 1117027 *10 n. 9 (D. Idaho March 20, 2014) involved an alleged refusal to extend financing which in turn was an alleged breach of contract under Idaho law. The Court in this case observed this about Idaho law, which is consistent with many other U.S. jurisdictions: "The covenant of good faith and fair dealing is a covenant in contract, not in tort. A claim for a breach of that covenant, therefore, sounds in contract and not in tort."
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