 A few states like California and Georgia have gone farther and attempted to codify all of their contract law (not just insurance law) into statutory law.Early insurance contracts were considered to be contracts like any other, but first English (see uberrima fides) and then American courts recognized that insurers occupy a special role in society by virtue of their express or implied promise of peace of mind, as well as the severe vulnerability of insureds at the time they actually make claims (usually after a terrible loss or disaster).In turn, the development of the modern cause of action for insurance bad faith can be traced to a landmark decision of the Supreme Court of California in 1958