Justices: Bad Faith Requires a Reason for Delay

Employers and insurers must know there is an unreasonable delay in payments to satisfy a claim of bad faith, the high court of South Dakota ruled. In McDowell v. Citicorp Inc., 23925-a-JKK, 06/06/2007, the South Dakota Supreme Court ruled that the claimant also did not explain what made her medical bill payment delays unreasonable and thus did not prove bad faith. The court wrote, "... McDowell's bad faith claim is premised on the fact that a certain number of days passed from the date she received treatment and the date the bill was finally paid. This, however, does not alone create a...