1.All insurance contracts contain a covenant of good faith and fair dealing.<\/p>\n

 2. If bad faith is a tort in a third-party claim, it should be a tort in a first-party claim as well.<\/p>\n

 3. Insurance is a matter of public interest and deserves special consideration by the courts to protect the public.<\/p>\n

 4. Insurance contracts are not like other contracts because insurers have an advantage in bargaining power. Insurers should therefore be held to a higher standard of care.<\/p>\n

 5. Recovery for breach of an insurance contract should not be limited to payment of the original claim.<\/p>\n

 6. The public’s expectations are elevated by the insurer’s advertising, slogans, and promises, which give policyholders the impression that they will be taken care of no matter what happens.<\/p>\n

 7. Policyholders buy peace of mind and are not seeking commercial advantage when they buy a policy. In addition, they are vulnerable at the time of the loss.<\/p>\n

 8. Policy language is sometimes difficult to understand. The benefit of the interpretation should be given to the policyholder.<\/p>\n<\/blockquote>\n