INSURANCE BAD FAITH

 Wisconsin law recognizes the tort of bad faith. Such actions are typically maintained for the insurer's (1) bad faith failure to pay; (2) bad faith investigations; (3) bad faith offer to settle with insured; or (4) bad faith failure to settle for insured tortfeasor. Thus, Wisconsin law provides for both first party and third party bad faith actions. Punitive damages are also available. Anderson v. Continental Ins. Co., 85 Wis. 2d 675, 271 N.W.2d 368 (1978); Mowry v. Badger State Mutual Ins. Co., 129 Wis. 2d 496, 385 N.W.2d 171 (1986); Upthegrove Hardware v. Pennsylvania Lumbermens Mutual, 146 Wis. 2d 470, 431 N.W.2d 689 (Ct. App. 1988).