The following excerpt is from Continental Re-Insurance Co. v. Spanton, 667 F.2d 1289 (9th Cir. 1982):
... that the company's refusal promptly to pay the claim was an extreme deviation from reasonable standards of conduct, performed with an understanding of its consequences.
Linscott v. Rainier National Life Ins. Co., 100 Idaho 854, 606 P.2d 958, 964 (1980) (footnote omitted).
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