Every insurance contract in New Jersey contains an implied covenant of good faith and insurance companies owe a duty of good faith to their insured in processing a first-party claim. A claim of bad faith in a first-party claim is an intentional tort in that it requires that the plaintiff show (1) the absence of a reasonable basis for denying benefits and (2) the carrier’s knowledge or reckless disregard of the lack of a reasonable basis for denying the claim. Thus, although bad faith is an intentional tort, the knowledge of a lack of reasonable basis may be inferred from a carrier’s reckless indifference to the facts.  Wadeer v. New Jersey Manufacturers Ins. (N.J. Supreme Court, February 2015)

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