The court found that the bad faith statute and common law claim for breach of the implied covenant of good faith did not apply to reinsurance agreements between sophisticated parties.
Date of Decision: October 10, 2007
Gaffer Ins. Co. v. Discover Reinsurance Co., No. 07-580, 2007 U.S. Dist. LEXIS 75259 (M.D. Pa. October 10, 2007) (Caputo, J.)