Lesher court explicitly stated it was not reaching—the threshold question of whether a claim for breach of the implied covenant of good faith and fair dealing could be brought in the absence of a potential for coverage. Id. at 187. The Court noted that “[n]either party has cited any case in which liability has been imposed on an insurer” for breach of the implied covenant of good faith and fair dealing for an inadequate defense in the absence of a potential for coverage. Id. Additionally, since Lesher, no California appellate decision has imposed liability for breach of the implied covenant of good faith and fair dealing for an inadequate defense in the absence of a potential for coverage. See, e.g., Imperial Cas. & Indem. Co. v. Sogomonian, 198 Cal.App.3d 169, 243 Cal.Rptr. 639 (1988) (<HOLDING>); cf. U.S. Fid. & Guar. Co. v. San Diego
recognizing that evidence of breach of implied covenant of good faith and fair dealing may support punitive damages holding where parties had not reached a binding contract the implied covenant of good faith and fair dealing did not apply recognizing cause of action for implied covenant of good faith and fair dealing in atwill employment contract holding that the implied covenant of good faith and fair dealing is limited to performance under a contract holding that assumption of defense cannot be basis for claim for breach of the implied covenant of good faith and fair dealing where contract had been rescinded