In Associated Indemnity Corp. v. CAT Contracting, Inc., 964 S.W.2d 276 (Tex. 1998), the supreme court considered a surety's duty of good faith to its principal. It concluded that, although no such duty existed at common law, such a duty did exist as a contract condition in the indemnity agreement before it where the indemnitee was given express authority to settle claims made in good faith. See id. at 278. The issue before the court was a sufficiency of the evidence challenge to the trial court's finding that the surety "acted in bad faith in investigating and settling the claims" with the owner. Id. at 282. The court analyzed "the appropriate definition of 'good faith' (and conversely, 'bad faith') under these circumstances." Id. at 284. The court considered whether a reasonable investigation was required and rejected that argument, stating, "In the surety context, bad faith requires more than an unreasonable or negligent investigation; it requires wilful misconduct or improper motive." Id. Relying on cases concerning settlement of claims by indemnitees in the commercial paper context, the court said: "We hold that "good faith" in the surety agreement before us refers to conduct which is honest in fact, free of improper motive or wilful ignorance of the facts at hand. It does not require proof of a "reasonable" investigation by the surety. Stating the proposition conversely for purposes of our evidentiary review for this particular case, "bad faith" means more than merely negligent or unreasonable conduct; it requires proof of an improper motive or wilful ignorance of the facts." Id. at 285.