The Perera decision:
An employer's liability insurer's actions neither caused the damages claimed by an insured nor resulted in exposure of the insured to liability in excess of the policy limits of three policies issued to the insured, the Florida Supreme Court held May 6, answering a rephrased certified question from the 11th Circuit U.S. Court of Appeals in the negative in finding that a cause of action for third-party bad faith against the insurer cannot be maintained (Source)