Skilskis on Cursor

plead a prima facie bad-faith claim that survives 12(b)(6) / demurrer in the situs state. walk egan, gruenberg, anderson, pickett, universe life, beck element variants — covenant existence, breach, knowledge, causation, damages — and translate into twombly-iqbal-compliant complaint counts.

diagnose whether the situs state recognizes insurer bad faith in tort (comunale/crisci lineage), contract-only (covenant-of-good-faith breach), or hybrid; controls damages ceiling, punitive availability, statute of limitations, and pleading caption. the structural fork that decides every other downstream question.

map state-by-state unfair claims settlement practices act (ucspa) variants of naic model #900, identifying private right of action, prohibited acts, cure-period prerequisites, and statutory penalty multipliers. drives whether the bad-faith case rides ucspa, common-law, or both.

build or defend a stowers-doctrine third-party bad-faith claim — insurer's failure to settle within policy limits exposing it to excess-judgment liability. validate the four-element stowers demand (within limits, unconditional, full release, ordinarily-prudent-insurer test) and lock excess-judgment damages.