Task: Wrong Candidate Generation
Input (English): bad faith breach of contract claim, it is clear that a state law bad faith cause of action against an ERISA provider is expressly preempted. In order to be characterized as a state law regulating insurance, the law must be “specifically directed toward that industry.” Pilot Life Ins. Co., 481 U.S. at 50, 107 S.Ct. 1549. Stated differently, the state law must “home[] in on the insurance industry.” Ward, 526 U.S. at 368, 119 S.Ct. 1380. The Iowa courts have not confined common law, bad faith causes of action to the insurance industry. Rather, it is a general law, applicable to the entire panoply of contracts. Accordingly, the plaintiffs’ common law bad faith cause of action is not saved from preemption by ERISA’s savings clause. See Pilot Life Ins. Co., 481 U.S. at 51, 107 S.Ct. 1549 (<HOLDING>), Kidneigh, 345 F.3d at 1186-87 (holding that 
 Holding statements: (A) holding that a bad faith claim is a tort (B) holding that improper motive is element of bad faith (C) holding that a state common law of bad faith was not integral to the insurerinsured relationship (D) holding title company liable for bad faith (E) holding that bad faith includes lack of good faith in investigating the facts of a complaint
Output (English): holding title company liable for bad faith