Does the implied covenant of good faith and fair dealing between a plaintiff and insurer apply to all insurance contracts?

The presence of this implied covenant as a part of all insurance contracts has been increasingly the source of spectacular jury awards based on tort theory such as to enable the imposition of exemplary damages. (See Fletcher v. Western National Life Ins. Co., 10 Cal.App.3d 376, 89 Cal.Rptr. 78, and its progeny.) Moreover, as stated in Gruenberg v. Aetna Ins. Co., 9 Cal.3d 566, 108 Cal.Rptr. 480, 510 P.2d 1032, '(w)e conclude, therefore, that the duty of good faith and fair dealing on the part of defendant insurance companies is an absolute one . . . (T)he nonperformance by one party of its contractual duties cannot excuse a breach of the duty of good faith and fair dealing by the other party while the contract between them is in effect and not rescinded.' (Id. at p. 578, 108 Cal.Rptr. at p. 488, 510 P.2d at p. 1040.)