Raitz v. State Farm Mut. Auto. Ins. Co., 960 P.2d 1179 (Colo.1998). This does not mean that a non-owner of a vehicle can provide the necessary consent to activate coverage. In both Wigles-worth and Raitz the policy holder was also the owner of the vehicle and the issues in both cases concerned the scope of the owner's initial consent, not whether a non-owner could provide the required consent. Wiglesworth, 917 P.2d at 289, 291; Raitz, 960 P.2d at 1181, 1188. The key issue here is who owned the truck at the time of the accident-Allen or Jackson. 12 . Some jurisdictions have concluded that expert testimony of industry standards is not required in actions alleging bad faith against an insurer. See, e.g., Bergman v. United Serv. Auto. Ass'n, 742 A2d 1101, 1107 (Pa.Super.Ct.1999) (<HOLDING>); Weiss v. United Fire and Cas. Co., 197 Wis.2d
holding expert testimony is not required as a per se rule  in bad faith actions holding that a bad faith claim is a tort holding such agreements to be per se illegal holding that per se statutory rule is not permissible under fourth amendment recognizing the intentional tort of bad faith in firstparty insurance actions