Larry O. Nichols, Respondent v. State Farm Mutual Automobile Insurance Company, Appellant

Summary

The South Carolina Supreme Court affirmed the jury verdict awarding Nichols actual and punitive damages for the insurer’s bad‑faith refusal to pay first‑party benefits, but vacated the award of attorneys’ fees. The Court recognized a tort cause of action for bad‑faith under the implied covenant of good faith, held that actual damages are not limited by the contract, and clarified procedural rulings on double recovery, election of causes, trial discretion, and fee awards.