The Connecticut Superior Court, Dooley, J., granted a motion to strike an insured’s bad faith claim in Trans-Clean Corp. v. Evanston Ins. Co., et al., No. FBT-CV-09-4028802 (Sept. 23, 2010).  In its complaint, the insured alleged that State Farm Mutual Automobile Insurance Company violated the duty of good faith and fair dealing by denying coverage and indemnification for an underlying suit pursuant to the provisions of its automobile liability policy.  When reaching its decision, the Court acknowledged that the majority of superior courts deciding what is necessary to plead a cause of action for bad faith have held that a plaintiff is required to plead factual specificity as to how the defendant’s actions were done in bad faith and in what manner the conduct was done with ill purpose, an intent to defraud or deceive, bad motive or violence.  Although a minority of superior courts have articulated a slightly more permissive approach, the Court ultimately determined that, under either standard, the allegations of the plaintiff’s complaint failed to sufficiently plead a claim of bad faith.  Indeed, the complaint did not contain any allegations that State Farm acted with ill purpose, bad motive or the intent to deceive or defraud.  In support of its bad faith claim, the plaintiff merely alleged that State Farm was not prejudiced by receiving untimely notice of the underlying claim.  The Court held that these allegations did not supply a sufficient basis for an inference of bad faith, but rather demonstrated the existence of a mere coverage dispute. Consequently, State Farm’s motion to strike was granted.