In many states, pleading and proving the existence of a valid contract is necessary for both a breach of contract cause of action and also for a viable bad faith claim, and the Alabama Supreme Court addressed exactly that issue last year in Alfa Life Ins. Corp. v. Kolza 159 So.3d 1240 (Ala., Aug. 22, 2014). The case involved a life insurance claim. The plaintiff’s decedent had applied for a policy and filled out an application that misstated his driving record. He then received a “Conditional Receipt” that afforded $100,000 in coverage while the application was pending. He was subsequently given a medical examination that disclosed high cholesterol levels and a family history of heart disease. He died in an…