a verdict and judgment against Zierle comprised of $15,000 in compensatory damages and $50,000 in punitive damages. Allstate proceeded to satisfy the compensatory component of the judgment only. As to the punitive-damages portion, Wolfe and Zierle entered into an agreement whereby Wolfe committed to forbear from executing in exchange for an assignment from Zierle of all claims arising under the policy which he might possess against Allstate. Relying upon this assignment, Wolfe proceeded to commence a civil action against Allstate in a Pennsylvania common pleas court, alleging that Allstate’s refusal to settle reflected bad faith on the carrier’s part. Wolfe sought damages under common-law contract theory, see Cowden v. Aetna Cas. & Sur. Co., 389 Pa. 459, 468, 134 A.2d 223, 227 (1957) (<HOLDING>), and per Section 8371 of the Judicial Code, 42
recognizing common law cause of action as thirdparty beneficiary recognizing a cause of action grounded in contract theory for badfaith refusal by an insurer to settle a thirdparty action recognizing cause of action recognizing wrongful adoption cause of action grounded in fraud and fraudulent misrepresentation recognizing the cause of action