San Antonio Court of Appeals Hampered by Unclear Texas Precedent on the Duty of Good Faith and Fair Dealing in Noninsurance Contracts: City of San Antonio v. Forgy, 769 S.W.2d 293 (Tex. App.-San Antonio 1989, writ denied)

Evaluates the San Antonio court of appeals case City of San Antonio v. Forgy. The author focused on the covenant of good faith and fair dealing discussing how the court dealt with the issue. In this instance, the San Antonio Court of Appeals held that the emerging Texas rule was that a duty of good faith and fair dealing is implied between contracting parties when a special relationship exists, but found no such relationship in the instant case.