Alternatively, she asserts that Jones established a confidential relationship with Fair-cloth “by her attitude and representations.” Faircloth obtained findings that Transport did not act in good faith and that the defendants breached a fiduciary duty owed her. Both theories depend on whether a special relationship arose between Transport and Faircloth. This Court has held that an insurer owes an insured a duty of good faith and fair dealing because of the special relationship arising out of the insurance contract. Aranda v. Insurance Co. of N. Am., 748 S.W.2d 210, 212 (Tex.1988). However, the Court has not squarely ruled on whether an insurer’s duty of good faith and fair dealing extends to a third-party claimant. See Allstate Ins. Co. v. Watson, 876 S.W.2d 145, 150 (Tex.1994) (<HOLDING>). Identifying a source of such a duty is
holding that duty of good faith and fair dealing did not extend to thirdparty claimant recognizing workers compensation insurance carrier owes employee duty of good faith and fair dealing in processing compensation claims holding that an insurer has a duty to act with the utmost good faith towards its insured holding that an insurer owes no duty of good faith to thirdparty claimants under the insurance code without reaching the question of a possible commonlaw duty holding that the duty of good faith and fair dealing is a contractual duty