Thanks for sharing this. Having read the case and statutes cited, I don't think it quite squares with your point.
Bad faith is a separate tort action recognized by most states for indefensible claims action/inaction by insurers. It is a distinct cause of action from the underlying tort claim, and they are very hard to win. I.e., the insurer has to eff up so egregiously that a jury would find a basis for separate damages beyond the underlying cause and find damages strictly due to the bad faith conduct. Two torts, two sets of damages. Yes in practice there is some correlation between damages in the underlying tort and the bad faith action, but it can easily take a different path. When the bad faith causes a much worse medical outcome, for example. Adjust claims within a basic framework of reasonableness and no bad faith claim would ever make it past summary judgment.
These kind of judgments are also entirely appealable. The court's opinion here denied review because the appellant failed to preserve the error below, a basic preservation error. That doesn't mean the issue cannot be appealed when done properly.