A federal trial court in Iowa confirmed that first-party bad faith claims may be cognizable against both insurers and self-insured employers. In Spencer v. Annett Holdings, Inc., 905 F.Supp.2d 953 (S.D. Iowa, Nov. 27, 2012), an over-the-road truck driver who was allegedly injured when he slipped and fell off the back of his flatbed trailer sued his employer, a self-insured trucking company, alleging, among other things, that it acted in bad faith by refusing to pay outstanding medical bills, by denying and delaying necessary medical care and treatment, and by breaching a settlement agreement approved by the Iowa Workers’ Compensation Commissioner. The trial court stated “[f]irst-party bad faith is an intentional tort that arises in the insurance context due to…