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1611 REVIEW DENIED In an insurance bad faith action, once the insured has validated a claim for emotional distress by proving that the carrier's bad faith led to an economic loss, the insured may recover for all emotional distress resulting from the bad faith, regardless of whether it resulted from the economic loss.CitationCLAYTON v UNITED SVCES (Bad Faith Distress) 54 CA4 1158 [See: Torres v Auto Club (REVIEW GRANTED) AT 8/95; Waters v United Svces 41 CA4 1063, T/AT 2/96; Gruenberg v Aetna 9 C3 566; Crisci v Security 66 C2 425]
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