NO COVERAGE, NO BAD FAITH.

To state it simply, it is almost universally held in the United States that where there is no insurance coverage, there is no bad faith.  See, e.g., Mounier v. RLI Corp., No. CV-19-01778-PHX-GMS, 2020 WL 263597, at *3 (D. Ariz. January 17, 2020).  This is the prevailing rule even in cases of alleged statutory bad faith under third-party or liability insurance policies, see in addition the hundreds of authorities discussed in 1 DENNIS J. WALL, LITIGATION AND PREVENTION OF INSURER BAD FAITH, § 3:28 (Thomson Reuters West 3d Edition & 2020 Supplements); or at common law or under various statutory causes of action alleged in first-party insurance cases, 2 id., § 9:3, titled The Question of Bad Faith (where the Mounier case is among those discussed), and § 9:14, titled Express Statutory Causes of Action.

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