Uniform Exclusion of Tort Bad‑Faith Claims for Service Warranties: America’s Car Mart v. The Honorable Damon Cantrell (Okla. 2025)

I. Introduction

The Oklahoma Supreme Court’s decision in America’s Car Mart, Inc. v. The Honorable Damon Cantrell, No. 122,581 (Okla. Oct. 14, 2025), resolves a significant question at the intersection of insurance law, consumer protection, and Oklahoma’s constitutional prohibition on “special laws.”

The core issue: Can Oklahoma’s Legislature validly eliminate the tort remedy for bad‑faith breach of a vehicle service warranty contract by declaring that such contracts are not “insurance” and by expressly barring tort claims, without violating the state constitutional ban on special laws?

The Court answers yes. It holds that:

Vehicle service warranty contracts governed (or treated as governed) by the Service Warranty Act, 15 O.S. §§ 141.1 et seq., are not insurance contracts for purposes of Oklahoma’s insurance bad‑faith doctrine.
15 O.S. § 141.24(B), which provides that such contracts do not create a “special relationship” supporting a tort claim for bad faith, is constitutional and not a prohibited special law under Article 5, § 46 of the Oklahoma Constitution.
The earlier decision in McMullan v. Enterprise Financial Group, Inc., 2011 OK 7, 247 P.3d 1173—holding that vehicle service warranty contracts could be treated as insurance and support tort bad‑faith claims—has been abrogated by statute.

Because the trial judge (Respondent, Judge Cantrell) had ruled that § 141.24(B) was an unconstitutional special law and had therefore refused to grant partial summary judgment to America’s Car Mart, the Supreme Court issues a writ of prohibition directing the trial court not to enforce that ruling and remands for further proceedings.

II. Factual and Procedural Background

A. The Parties and the Underlying Dispute

The real parties in interest, Linda and Jerimee Naquin, purchased a used 2012 Dodge Durango SUV from America’s Car Mart, Inc. (ACM), a foreign corporation operating in Oklahoma. Along with the vehicle, they purchased a separate vehicle service contract (a “service warranty” in the statute’s terminology).

The Naquins allege that over approximately a year:

They returned the SUV to ACM numerous times for repairs.
They were repeatedly charged the contractual deductible.
ACM prevented them from communicating directly with the repair shop.
Necessary repairs were not made, and ACM falsely represented that the vehicle had been fixed.

In December 2022, they sued ACM asserting:

Breach of contract;
Breach of warranty;
Breach of the duty of good faith and fair dealing—a tort claim patterned on Oklahoma’s well‑developed insurer bad‑faith doctrine.

The case thus raises the question whether a vehicle service warranty holder may pursue the same type of tort bad‑faith claim available against insurers.

B. The Motion for Partial Summary Judgment and the Constitutional Issue

ACM moved for partial summary judgment, arguing that the Naquins’ tort claim for breach of the duty of good faith and fair dealing is barred by 15 O.S. § 141.24(B)—a key provision of the 2012 Service Warranty Act.

Both sides agreed that if § 141.24(B) is constitutional, it governs this case and prohibits a tort bad‑faith claim based on a service warranty. The dispute pivoted entirely to the constitutional validity of that section.

Judge Cantrell held that § 141.24(B) is an unconstitutional special law under Article 5, § 46 of the Oklahoma Constitution and denied ACM’s motion for partial summary judgment.

C. The Writ Proceedings

The parties entered an Agreed Interlocutory Order on June 5, 2024, memorializing the March 5 ruling and certifying the constitutionality issue for interlocutory appeal under 12 O.S. § 952(b)(3). ACM filed, then voluntarily dismissed, an interlocutory appeal before seeking extraordinary relief:

a writ of prohibition, to prevent enforcement of the unconstitutional‑ruling order; and
a writ of mandamus, to compel the trial court to grant ACM’s motion.

Citing the standards from Maree v. Neuwirth, 2016 OK 62, 374 P.3d 750, the Court addresses whether the trial judge exercised judicial power not authorized by law and whether ACM lacks an adequate remedy other than a writ. Ultimately, the Court grants a writ of prohibition (not mandamus) and remands the case for further proceedings consistent with its opinion.

III. Summary of the Opinion

At a high level, the Court’s holdings are:

Vehicle service warranties are not insurance contracts under current Oklahoma statutes.
The 2012 Service Warranty Act, enacted in direct response to McMullan, explicitly provides that service warranties “are not insurance” and are not regulated under the Oklahoma Insurance Code (15 O.S. § 141.2(17)(f)). This removes them from the scope of pre‑existing insurance bad‑faith doctrines that depend on their being “insurance.”
15 O.S. § 141.24(B) bars tort bad‑faith claims related to all service warranties in a constitutionally permissible way.
Section 141.24(B) states that a “service warranty and those contracts specified in subparagraphs a through e of paragraph 17 of Section 141.2” do not create a “special relationship” that would support an action in tort for breach of the duty of good faith and fair dealing, though contract claims for breach of an implied duty remain available. This provision applies uniformly to an entire class of contracts and is, therefore, a general law, not a special law, under Article 5, § 46.
McMullan v. Enterprise Financial Group, Inc. has been abrogated by statute.
McMullan treated vehicle service warranties as “insurance” due to a statutory gap. The Legislature filled that gap by enacting the Service Warranty Act and by expressly disassociating service warranties from the Insurance Code. The Court recognizes that this legislative action has superseded McMullan for contracts within the Act’s reach.
Section 141.24(B) does not violate the constitutional prohibition on special laws limiting civil actions or regulating the practice or jurisdiction of courts.
Applying the test from Reynolds v. Porter, Zeier v. Zimmer, Inc., and Beason v. I.E. Miller Services, Inc., the Court holds that the statute applies to all members of a properly defined class—service warranty contracts and similar agreements—and does not arbitrarily single out any favored or disfavored subset. Therefore, it is a valid general law.
The trial court’s ruling is an unauthorized exercise of judicial power, warranting a writ of prohibition.
Because Section 141.24(B) is constitutional, the trial court lacked authority to disregard it as void. Continuing to adjudicate a tort bad‑faith claim contrary to a valid statute would be an unauthorized exercise of judicial power. A writ of prohibition is issued to prevent enforcement of the unconstitutional ruling.

IV. Statutory and Doctrinal Framework

A. Oklahoma Insurance Bad‑Faith Law and the “Special Relationship”

Oklahoma is well known for its robust insurance bad‑faith tort, originating with Christian v. American Home Assurance Co., 1977 OK 141, and further developed in subsequent cases. That doctrine is built on the idea that:

An insurance contract creates a “special relationship” between insurer and insured.
That special relationship gives rise to an implied covenant of good faith and fair dealing.
A violation of that covenant is not merely a breach of contract; it can support a tort action for bad faith, including punitive and extra‑contractual damages.

This “special relationship” has been recognized for insurance and certain quasi‑insurance contexts, but not for all commercial contracts. The question in McMullan—and again in this case, before the 2012 statute was considered—was whether a vehicle service warranty should be treated similarly to insurance.

B. McMullan and the Pre‑2012 Regime

In McMullan v. Enterprise Financial Group, Inc., 2011 OK 7, 247 P.3d 1173, the Court faced a statutory gap. The Oklahoma Insurance Code did not specifically address vehicle service warranties. The Court reasoned that:

The extent of regulatory oversight is not, by itself, dispositive of whether something is “insurance.”
In function, vehicle service warranties protect consumers from specified vehicle‑related expenses, operating similarly to insurance policies.
Absent a statutory exclusion, such contracts could be treated as insurance for purposes of the Insurance Code and the insurer’s duty of good faith.

Thus, under McMullan, vehicle service contracts could support tort actions for bad‑faith breach of the implied covenant, as though they were insurance contracts.

C. The 2012 Service Warranty Act

The Legislature responded “in direct response to McMullan” by enacting the Service Warranty Act in 2012, codified at 15 O.S. §§ 141.1–150. Key features relevant here include:

Express declaration that service warranties are not insurance.
15 O.S. § 141.2(17)(f) states that “service warranties are not insurance” and are not regulated under the Oklahoma Insurance Code, removing them from the purview of insurance law and, by implication, the insurance bad‑faith doctrine.
Narrow statutory definition of “service warranty.”
15 O.S. § 141.2(17)(e) tightly defines what constitutes a “service warranty,” but expressly excludes warranties, guarantees, extended warranties, or service contracts issued by companies with assets in excess of $100 million. Those high‑asset companies’ contracts are generally outside the Act’s regulatory framework.
Broad prohibition on tort bad‑faith claims: § 141.24(B).
The central provision in this case, 15 O.S. § 141.24(B), provides:
A service warranty and those contracts specified in subparagraphs a through e of paragraph 17 of Section 141.2 of this title shall not be deemed to create a special relationship between the parties which would give rise to an action in tort to recover for breach of the duty of good faith and fair dealing. This section shall not be construed to preclude a breach of contract action for failure of the parties to comply with the implied duty of good faith and fair dealing in carrying out their obligations as set forth in the service warranty.
This ensures that:
- There is no tort remedy for bad faith; and
- Contract remedies based on breach of an implied duty of good faith remain available.
- The prohibition applies not only to statutory “service warranties” but also to the contracts excluded in § 141.2(17)(e), including those issued by large, high‑asset companies.

The present case tests the constitutional validity of this broad bar on tort bad‑faith actions.

V. Precedents Cited and Their Role

A. McMullan v. Enterprise Financial Group, Inc. (2011 OK 7)

McMullan is central because it:

Held that vehicle service warranty contracts, though not explicitly labeled “insurance,” functioned sufficiently like insurance to be treated as such under the Insurance Code.
Concluded that these contracts could support tort actions for breach of the insurer‑like duty of good faith and fair dealing.
Triggered the Legislature’s 2012 response: creating the Service Warranty Act and declaring such contracts outside the Insurance Code.

The Court here emphasizes:

In McMullan, the Court was filling a statutory gap in the absence of specific legislative direction.
Once the Legislature adopted a new, specific statutory framework, judicial construction gave way to legislatively defined categories—and the legislative policy choice controls.
Section 141.24(B) is “unequivocal” in abrogating McMullan as a matter of statutory policy.

B. Sparks v. Old Republic Home Protection Co., Inc. (2020 OK 42)

The Naquins invoked Sparks to suggest that this Court had cast doubt on the continuing vitality of the Service Warranty Act or of McMullan. The Court refutes this characterization.

In Sparks, the issue was:

Whether a home service warranty was a “warranty” or a “service contract” under the Home Service Contract Act, not the Service Warranty Act.
The Court concluded that the home warranty at issue was a warranty, not a service contract, therefore not subject to that Act.

In doing so, Sparks analogized to McMullan primarily on the conceptual distinction between insurance and service contracts, but:

Sparks did not opine on the validity of the Service Warranty Act.
Sparks did not undermine or re‑affirm McMullan as a governing rule post‑2012.

The 2025 Court clarifies that any suggestion that Sparks preserved McMullan in the face of the 2012 statute is mistaken.

C. Writ Standards: Maree v. Neuwirth (2016 OK 62)

Maree v. Neuwirth supplies the governing standards for extraordinary writs:

Writ of prohibition requires:
- Exercise of judicial power not authorized by law; and
- Resulting injury for which there is no other adequate remedy.
Writ of mandamus requires:
- A clear legal right in the petitioner;
- A plain legal duty in the respondent;
- A failure to perform that duty;
- No discretion involved; and
- No adequate remedy at law.

Although ACM sought both prohibition and mandamus, the Court grants only a writ of prohibition, focusing on preventing enforcement of the unconstitutional‑ruling order rather than directly compelling entry of summary judgment.

D. “Special Laws” Jurisprudence: Reynolds, Zeier, and Beason

Article 5, § 46 of the Oklahoma Constitution prohibits “special laws” on several topics, including laws that:

Limit civil actions;
Regulate the practice or jurisdiction of courts; or
Change the rules of evidence.

The cases cited define and apply this doctrine:

Reynolds v. Porter, 1988 OK 88, 760 P.2d 816
A general law “includes all persons or things of a class.” A special law arbitrarily singles out a subset for different treatment without a legitimate basis.
Zeier v. Zimmer, Inc., 2006 OK 98, 152 P.3d 861
Elaborates that the test is whether the provision fits “into the structured regime of established procedure as part of a symmetrical whole.” A special law disrupts that symmetry by singling out particular parties or claims.
Beason v. I.E. Miller Services, Inc., 2019 OK 28, 441 P.3d 1107
Reiterates that a special law is one that “arbitrarily singles out a particular classification of persons or things for different treatment than is given to all others similarly situated.”

These cases guide the Court’s conclusion that § 141.24(B) is a general, not special, law because it applies uniformly to the entire class of service warranty‑type contracts.

VI. The Court’s Legal Reasoning

A. Vehicle Service Warranties Are Not Insurance Contracts After 2012

The Court begins by reaffirming that, prior to 2012, vehicle service warranty contracts were governed by the Insurance Code only by judicial inference in McMullan, which looked to their function and the absence of a specific statutory framework.

But the Legislature responded:

Enacting the Service Warranty Act in 2012;
Defining “service warranties” narrowly (15 O.S. § 141.2(17)(e));
Stating expressly that “service warranties are not insurance” and are not regulated under the Insurance Code (15 O.S. § 141.2(17)(f)).

The Court recognizes that legislative classifications control in defining legal categories unless they violate constitutional limits. Thus, regardless of functional similarities, vehicle service warranties are no longer “insurance” for statutory purposes. As a result:

They do not fall within the insurance‑specific duties and remedies, including insurance bad‑faith tort claims.
Any earlier judicial characterization in McMullan has been superseded as a matter of statutory law.

B. Statutory Abrogation of McMullan

The Court emphasizes the principle that while courts interpret statutes, the Legislature has the prerogative to amend or reshape statutory law. In McMullan, the Court filled a gap; in 2012, the Legislature closed that gap and adopted a contrary policy:

Service warranties are explicitly not insurance.
A broad prohibition on tort bad‑faith actions was enacted in § 141.24(B).

The Court concludes that this legislative response abrogates McMullan as it applies to contracts within the Service Warranty Act’s scope. The opinion expressly states: “This language is unequivocal: McMullan has been abrogated by statute.”

In practical terms:

McMullan may still govern older, pre‑2012 contracts or contexts not covered by the Service Warranty Act.
For contracts issued after the Act, like the Naquins’ vehicle service contract, the statute—not McMullan—controls.

C. Section 141.24(B) and the “Special Law” Challenge

1. The challengers’ argument

The Naquins do not attack the entire Service Warranty Act, but claim:

Section 141.24(B), which eliminates tort bad‑faith claims for service warranties, is a special law that unconstitutionally limits civil actions or regulates the practice and jurisdiction of courts.
They frame the relevant “class” as “all persons who have insurance”; from that perspective, holders of service warranties are singled out and treated worse because they cannot bring tort bad‑faith claims.

2. Redefining the relevant class

The Court rejects this characterization, noting that the challengers’ “all insurance holders” framing is inconsistent with the Legislature’s valid policy choice to:

Create a distinct legal category for service warranties; and
Declare that service warranties are not insurance.

For special‑law analysis, the key question is not whether service warranty holders are treated the same as insurance policyholders, but whether the statute:

Defines a reasonable class; and
Treats all members of that class uniformly.

Here, the relevant class is: all agreements issued as, resembling, or functioning as service warranties under the Service Warranty Act—including those otherwise excluded from the Act’s regulatory provisions by the $100 million asset carve‑out.

3. Uniform coverage of the class

The Court focuses on how § 141.24(B) operates across that class:

Section 141.2(17)(e) excludes from the definition of “service warranty” contracts issued by companies with assets over $100 million, removing them from most of the Act’s regulatory requirements.
However, § 141.24(B) is drafted to apply not only to statutory “service warranties” but also to “those contracts specified in subparagraphs a through e of paragraph 17 of Section 141.2”—which includes the high‑asset companies’ contracts.

Thus, every agreement in the service‑warranty universe—including contracts of large, well‑capitalized issuers—is subject to the same rule: no tort bad‑faith cause of action based on a “special relationship.”

The Court notes that the Legislature could have done the opposite:

It could have allowed tort bad‑faith claims only against high‑asset companies’ service warranties, while prohibiting them for smaller entities.
Such a carve‑out would have “singled out those particular companies’ warranties for special treatment”—the hallmark of a special law.

Instead, the Legislature chose a uniform rule across all service‑warranty‑type contracts. This uniformity is decisive for the special‑law analysis.

4. Fitting within a “symmetrical whole”

Invoking Zeier, the Court asks whether § 141.24(B) is part of a “structured regime of established procedure as part of a symmetrical whole.” It concludes that:

The Service Warranty Act establishes a coherent, specialized regime distinct from the Insurance Code.
Section 141.24(B) is an integral component of that regime: it defines the remedy structure applicable to all service‑warranty‑type contracts.
By universally precluding tort bad‑faith claims while preserving contract remedies, the statute fits symmetrically into that regulatory framework.

Accordingly, the Court holds that § 141.24(B) is a general law and does not violate Article 5, § 46.

D. Preservation of Contract‑Based “Good Faith” Claims

The Court is careful to note that § 141.24(B) does not eliminate the implied duty of good faith and fair dealing altogether. Instead:

The statute bars only tort claims premised on a “special relationship” between the parties.
It explicitly “shall not be construed to preclude a breach of contract action for failure of the parties to comply with the implied duty of good faith and fair dealing in carrying out their obligations.”

Thus, service warranty holders retain:

Traditional contract damages for breach, including potentially consequential damages if provable under contract law; but
No tort remedies such as punitive damages or extra‑contractual damages available under the insurance bad‑faith doctrine.

E. The Writ of Prohibition

Applying Maree, the Court finds the conditions for a writ of prohibition satisfied:

By declaring § 141.24(B) unconstitutional and proceeding as though a tort bad‑faith claim exists, the trial court exercised judicial power not authorized by law, because:
- Inferior courts must apply valid statutes unless and until properly held invalid under constitutional standards.
- Here, the Court finds the statute constitutional, making the trial court’s refusal to apply it an overreach.
ACM lacks an adequate remedy short of a writ because:
- Absent interlocutory review, it would be forced to litigate a tort claim and potentially face punitive‑type exposure under a theory barred by a valid statute.
- A post‑judgment appeal, while theoretically possible, would not undo the burdens and risks of having to defend a claim that the law does not allow.

The Court therefore:

Grants a writ of prohibition, precluding enforcement of the June 5, 2024 Order denying ACM’s motion for partial summary judgment; and
Remands the case to the trial court for further proceedings consistent with its opinion.

VII. Simplifying Key Legal Concepts

Vehicle Service Warranty / Service Contract: A contract under which a company agrees, for a fee, to pay for or perform certain repairs or services on a vehicle over a period of time or mileage. It is not the same as the manufacturer’s original warranty. In Oklahoma, such agreements are governed by the Service Warranty Act and are explicitly not “insurance”.
Insurance Contract: A contract where an insurer, in exchange for premiums, agrees to pay for certain losses or liabilities (for example, auto accidents, health care costs, property damage). In Oklahoma, insurance contracts are heavily regulated under the Oklahoma Insurance Code and are subject to the tort of bad faith because of the special relationship with the insured.
Tort of Bad Faith / Breach of the Duty of Good Faith and Fair Dealing (Insurance Context): A cause of action in tort (not just contract) that allows an insured to seek extra‑contractual and punitive damages when an insurer unreasonably delays or denies payment of a valid claim or otherwise fails to deal fairly and in good faith. It arises from a special relationship between insurer and insured.
Implied Duty of Good Faith and Fair Dealing (Contract Context): A background rule of contract law: parties must act honestly and fairly in performing their contractual obligations. Breach of this implied duty is treated as a breach of contract, usually leading only to contract‑type damages (for example, compensation for actual losses), not tort or punitive damages—unless a special doctrine like insurance bad faith applies.
Special Relationship: A legal term used in Oklahoma to describe relationships (like insurer–insured) where the parties’ roles and vulnerabilities justify imposing duties beyond ordinary contract obligations. These relationships support tort remedies for bad‑faith breach, not merely contract remedies.
Special Law (Oklahoma Constitution, Art. 5, § 46): A law that arbitrarily singles out certain persons or entities for different treatment from others in the same situation. Article 5, § 46 forbids special laws on certain subjects, including limiting civil actions or regulating courts’ practice or jurisdiction. A general law validly defines a class and treats all class members the same.
Writ of Prohibition: An extraordinary remedy from a higher court stopping a lower court from acting outside its lawful authority. When granted, it prevents the lower court from enforcing orders or conducting proceedings that are unauthorized by law.
Writ of Mandamus: An extraordinary order compelling a public official or court to perform a plain, non‑discretionary duty that the law requires. It is not granted when the act involves judicial discretion or when an adequate remedy (like appeal) exists.

VIII. Likely Impact and Future Litigation

A. Impact on Consumers and Service Warranty Holders

For consumers like the Naquins, this decision has concrete consequences:

No tort bad‑faith actions are available for disputes arising out of vehicle service warranties or contracts treated as such.
Consumers are limited to contract‑based remedies—they may still:
- Sue for breach of the warranty or service contract;
- Assert breach of the implied duty of good faith and fair dealing as a contract claim (not tort); and
- Seek contract damages, including those reasonably within the contemplation of the parties.
However, they typically cannot pursue:
- Punitive damages grounded in insurer‑style bad faith; or
- Standalone tort claims for emotional distress or similar harms tied solely to the service warranty’s nonperformance.

B. Impact on Service Warranty Providers and High‑Asset Companies

For providers like ACM and other service warranty issuers:

The decision provides significant litigation certainty: regardless of company size or asset level, service warranty disputes will be litigated as contract cases, not insurer bad‑faith cases.
This greatly narrows potential liability exposure, especially regarding punitive and extra‑contractual damages.
Large, high‑asset companies previously excluded from some regulatory requirements under § 141.2(17)(e) are clearly covered by the tort‑remedy exclusion in § 141.24(B), avoiding any claim that they can be specially targeted for bad‑faith claims.

C. Clarification for the Courts and the Bar

Doctrinally, the decision:

Confirms that McMullan is no longer controlling for post‑2012 vehicle service warranty contracts—this will shape legal strategies in future warranty litigation.
Clarifies that Sparks does not undermine the Service Warranty Act or revive McMullan where the Act applies.
Provides a clear signal to trial courts: attempts to re‑characterize service warranties as insurance to access tort bad‑faith remedies are contrary to the statutory scheme and now definitively rejected.

D. Development of Oklahoma’s Special‑Law Jurisprudence

Constitutionally, this case modestly but clearly advances Oklahoma special‑law doctrine by:

Reaffirming that the Legislature may create distinct legal categories (for example, “service warranties” vs. “insurance”) as long as the laws governing each category operate uniformly within that class.
Emphasizing that the mere fact that a new category has fewer remedies than another (service warranties vs. insurance) does not make the law “special” under Article 5, § 46, provided all members of the new category are treated the same.
Underscoring that a law may be more restrictive or remedially limited than common law without being unconstitutional, so long as it survives the special‑law test and any other applicable constitutional scrutiny.

E. Potential Areas of Future Litigation

Though this opinion answers many questions, others may arise, such as:

Boundary disputes over what counts as a “service warranty” or as “those contracts specified in subparagraphs a–e” of § 141.2(17), particularly for hybrid products.
Whether creative claims (for example, fraud, deceptive trade practices, or negligence separate from the contract duties) can still be asserted despite § 141.24(B), provided they do not rest on a “special relationship” theory.
How courts will measure contract damages for breach of the implied duty of good faith and fair dealing when tort remedies are off the table.

Nonetheless, the Court’s opinion significantly narrows the field by firmly precluding classic insurer‑style bad‑faith tort claims in the service‑warranty context.

IX. Conclusion

America’s Car Mart v. Cantrell is a pivotal case in Oklahoma’s law of service warranties and special‑law constitutional doctrine. It holds that:

Vehicle service warranties and similar contracts, as defined in the Service Warranty Act, are not insurance and therefore do not support the tort of bad faith based on a special relationship.
15 O.S. § 141.24(B), which broadly eliminates tort bad‑faith actions while preserving contract‑based good‑faith claims, is a general, not special, law and is constitutional under Article 5, § 46.
The Legislature validly abrogated McMullan by enacting the Service Warranty Act, displacing prior judicial assumptions about service warranties being treated as insurance.
The trial court’s contrary ruling was an unauthorized exercise of judicial power, properly corrected by a writ of prohibition.

In the broader legal context, this decision reinforces:

The Legislature’s authority to reshape remedial schemes and reclassify contractual relationships, so long as constitutional constraints—especially the ban on special laws—are respected.
The limited nature of the insurance bad‑faith tort: it is an exception grounded in a narrow class of relationships, not a general remedy for all disappointed contracting parties.
The continuing importance of Oklahoma’s special‑law jurisprudence in mediating the balance between legislative innovation and constitutional equality in the treatment of similarly situated parties.

For practitioners, the message is clear: in disputes over vehicle service warranties and comparable agreements covered by the Service Warranty Act, remedies lie in contract, not in the tort of insurer‑style bad faith.

Uniform Exclusion of Tort Bad‑Faith Claims for Service Warranties: America’s Car Mart v. Cantrell and Oklahoma’s Service Warranty Act