This rule is now enacted in all but two of the states of the United States; the history of its development and of its application since it became undisputed is well illustrative of the process of the common law system, and this discussion is undertaken for the purpose of discovering the general principles which a trial court should have in mind when charging a jury in a case involving the application of this doctrine.
George W. Rightmire,
Doctrine of Bad Faith in the Law of Negotiable Instruments,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol18/iss5/2