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4764 A tort action for breach of the implied covenant of good faith and fair dealing in a contract of insurance may be brought regardless of whether the insurer has breached an express provision of the contract; an insurer may be liable for delaying payment of policy benefits unless there is a genuine dispute regarding whether or in what amount they are owed, and the insurer's position in the dispute is reasonable and reached in good faith.CitationBREHM v 21st CENTURY (Bad Faith) 166 CA4 1225 [See: InsC 11580.2, 11580.26; CCP 581d; Comunale v Traders 50 C2 654; Wilson v 21st Century 42 C4 713, T/AT 1/08; Chateau Chamberay v Associated 90 CA4 335, T/AT 8/01]
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