In Carmichael v. Adirondack Bottled Gas Corp., 161 Vt. 200, 635 A.2d 1211 (1993), the duty that was breached arose from a written contract for a petroleum gas distributorship. Id. at 202, 635 A.2d at 1213. Thus, Carmichael is completely inapposite.
As the Court explained, the duty of good faith "is a concept that varies . . . with the context in which it is deemed an implied obligation." Carmichael, 161 Vt. at 208, 635 A.2d at 1216.