N.D. Cent. Code § 26.1-39-29
26.1-39-29. Civil remedy actions against property insurers
26.1-39-29. Civil remedy actions against property insurers
Notwithstanding any provision under title 26.1, before a named insured may proceed with a
bad faith claim against a property insurer, the named insured shall establish through an adverse
adjudication by a court of law the property insurer breached the insurance contract and a final
judgment or decree must have been rendered against the insurer.