Holy Trinity Greek Orthodox Church v. Church Mut. Ins. Co., 2007 WL 706960 (D.Ariz., 2007) involves insurance claims made by the plaintiff Holy Trinity after a water pipe broke at Holy Trinity's education center. The defendant, Church Mutual, provided Holy Trinity with first-party property insurance coverage, and Holy Trinity alleged claims of bad faith and breach of covenant of good faith and fair dealing against Church Mutual.

Church Mutual moved for partial summary judgment on the punitive damages claim , arguing that there was “simply no basis given the facts of this case to find that Church Mutual was guided by evil motives or willful or wanton disregard of the interests of its insured“.