Brewer

I. BACKGROUND

Brewer was insured under an automobile insurance policy issued by Allstate. She sustained injuries on July 29, 2013, and

1 claimed that a hit-and-run driver had struck her vehicle as she was traveling eastbound on Highway 24 and pushed her car into the rear end of another vehicle. She claimed coverage under the UM section of her policy. On July 24, 2015, Brewer demanded that Allstate arbitrate her UM claim under Insurance Code section 11580.2, subdivision (f).1 Four days later, on July 28, 2015, she filed a complaint against Allstate in superior court, containing causes of action for (1) personal injury—motor vehicle/uninsured motorist damage; (2) breach of contract; (3) contractual breach of the implied covenant of good faith and fair dealing; (4) tortious breach of the implied covenant of good faith and fair dealing; (5) bad faith and (6) unfair trade practices. Following an arbitration, the arbitrator issued an award on October 29, 2018, stating that Brewer would “take nothing by way of her claim.” In a letter addressed to all counsel for the parties dated November 9, 2018, the arbitrator explained the reason for his award: “I have concluded that claimant has…