fail ’ bad faith and callous disregard for Gilmore’s right to purchase the business based on Mrs. Duderstadt’s testimony that, after their retirement, the Duderstadts continued using Laubo’s corporate credit card for their personal use, including vacations and car repairs, and charged these expenditures against Gilmore’s net profit during the trial period. Finally, the evidence of the Duderstadts demanding an additional $200,000 to allow Gilmore to proceed, could reasonably be seen as evidence of bad faith and overreaching on their part. {31} Therefore, we conclude that Gilmore presented sufficient evidence of the Duderstadts’ culpable mental state so as to require the trial court to instruct the jury on the issue of punitive damages. See Romero, 109 N.M. at 257, 784 P.2d at 1000 (<HOLDING>). The trial court erred in refusing to submit
holding that a duty of good faith and fair dealing is implied in insurance contracts in pennsylvania and allows for the award of compensatory damages pursuant to a breach of contract claim in a first party insurance case explaining that the difference between first and third party claims does not matter to the implied covenant of good faith and fair dealing recognizing that evidence of breach of implied covenant of good faith and fair dealing may support punitive damages holding that negligence alone is not sufficient to constitute a breach of the implied covenant of good faith and fair dealing owed to insureds holding that the implied covenant of good faith and fair dealing is limited to performance under a contract recognizing cause of action for implied covenant of good faith and fair dealing in atwill employment contract