Tracy Garcia authored the Expert Analysis Column "Full Policy Payment May Not Bar Insurer Bad Faith In 9th Circ." for Law360. The article examines the Ninth Circuit’s recent decision in Quilbillies LLC v. First American Title Insurance Co., where a divided panel held that an insurer’s payment of the full policy amount, while satisfying its contractual obligations, did not necessarily eliminate a bad faith claim.
In the article, Tracy highlights the practical significance of the decision for insurers. Although acting within the express terms of a policy may resolve a breach-of-contract claim, the insurer’s conduct before and surrounding that contractual performance may still be scrutinized for potential bad faith and extracontractual liability.
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