insurer where there has been a bad-faith refusal to settle resulting in an excess verdict, see Cowden, 389 Pa. at 468, 134 A.2d at 227; Gray v. Nationwide Mut. Ins. Co., 422 Pa. 500, 511, 223 A.2d 8, 13 (1966), Allstate denominates attempts to assign exemplary entitlements under Section 8371 as champertous. In this line of argument, Allstate highlights that Pennsylvania courts have manifested a particular aversion to assignment of personal causes of action seeking penalties. See, e.g., Sensenig, 229 Pa. at 173, 78 A. at 92 (“Counsel for appellant practically admit that the treble damages imposed by the act of 1883 are to be regarded as a penalty, and that the right to such damages is not assignable.”); Osborn v. First Nat’l Bank of Athens, 175 Pa. 494, 498-99, 34 A. 858, 859 (1896) (<HOLDING>). Allstate recognizes that there are
holding that nonconsensual oversecured tax claim is entitled to the statutory rate of interest unless the statutory rate constitutes a penalty holding that pursuant to the same perfectly plain language of the statutory predecessor of code  18218 the defendant could properly be convicted as an accessory before the fact on an indictment charging statutory burglary holding that accruing interest at the default interest rate was not a penalty but the addition of a 5 late charge on top of the default interest would have been unreasonable pursuant to  506b and would have therefore been a penalty holding that the right to pursue a statutory penalty for charging usurious interest was unassignable holding that the penalty is applicable