 In 1979, California's highest court refuted that argument and further expanded the scope of the tort by holding that inadequate "investigation" of a claim was actionable in tort as a breach of the implied covenant of good faith and fair dealing.Other state courts began to follow California's lead and held that a tort claim exists for policyholders that can establish bad faith on the part of insurance carriers.By the late 1990s, courts in nearly thirty states recognized the claim.