In Rocanova v. Equitable Life Assur. Socy. of U.S. (83 NY2d 603, 634 NE2d 940, 612 NYS2d 339 [1994]), the Court rejected the argument that a bad faith failure by an insurer to pay a claim could, without more, justify a punitive damages award. The Court held that punitive damages are not available for breach of an insurance contract unless the plaintiff shows both "egregious tortious conduct" directed at the insured claimant and "a pattern of similar conduct directed at the public generally" (Rocanova, 83 NY2d at 613; see NYU, 87 NY2d at 316).