In Colwell v. MCNA Ins. Co., 960 N.W.2d 675 (Iowa 2021) (emphasis in original), the unlabeled synopsis at the outset of the published decision, printed even above the identification of the Justice who wrote the opinion for the Court, states:
The defendants appeal the district court's ruling in favor of the plaintiff finding breach of contract and breach of implied covenant of good faith and fair dealing. AFFIRMED.
The Iowa Supreme Court's opinion refers only to the breach of contract conduct, so far as I can find from reading the opinion. When the Supreme Court unanimously affirmed the trial court's bench-trial judgment for the plaintiff on the plaintiff's breach of contract claim, necessarily they also unanimously affirmed the trial court's judgment for the plaintiff on the plaintiff's claim for breach of the implied covenant of good faith and fair dealing.
Judgment was entered by the trial court on both claims, it appears. Therefore, an appeal from that judgment was an appeal from judgment for the plaintiff on both claims, and so the Supreme Court's affirmance of the trial court's judgment was an affirmance of judgment for the plaintiff on both claims.
Apparently in some cases at least, breach of the implied covenant and breach of contract can result in a judgment on both claims, such that appealing the judgment decides the appellate fate of not one but both of the claims.
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