De La Concha of Hartford, Inc. v. Aetna Life Insurance Company
Connecticut Supreme Court
849 A.2d 382 (2004)
Aetna (defendant), having lost nearly $50 million over 20 years operating a mall it owned, began transitioning tenants to short-term leases while trying to sell the property; De La Concha (plaintiff), a struggling tenant unable to meet the lease's minimum annual sales requirement for renewal due to declining profits amid a weak local economy, sued after Aetna rejected its attempt to exercise a five-year renewal option, alleging Aetna deliberately starved out tenants by failing to maintain and promote the mall to force a sale. The trial court ruled for Aetna, and De La Concha appealed.
Whether, in Connecticut, a plaintiff alleging a breach of the implied covenant of good faith and fair dealing must show that the defendant acted in bad faith with a design to mislead, deceive, or attempt to impede some contractual obligation through some sinister motive or with a dishonest purpose.