Dolan v. Aid Insurance Co.

SNELL, Justice.

This appeal raises an issue which has recurrently been before this court: whether we will recognize a cause of action in tort against an insurance carrier for bad faith conduct relating to a claim made by its insured. Although we have recognized a cause of action against an insurer for bad faith in its representation of an insured against a third-party claim, Kooyman v. Farm Bureau Mut. Ins. Co., 315 N.W.2d 30, 33-34 (Iowa 1982), we have consistently found it unnecessary to adopt or reject the tort of bad faith in the first-party situations. Hoekstra v. Farm Bureau Mut. Ins.…