context: However, an insured's conduct can vitiate good faith even without subjective dishonesty, actual knowledge of, or complicity in the forgery. If an insured's conduct rises past ordinary negligence to the level of gross negligence or knowing indifference to "red flags," it breaches the good faith requirement.
citation_a.signal: see also
citation_a.parenthetical: suggesting that "extending] credit based on documents that look[ ] suspicious" would be bad faith
citation_a.sentence: See Marsh Inv. Corp. v. Langford, 721 F.2d 1011, 1014 (5th Cir.1983) (“[M]ere ignorance is not bad faith, but ... if one chooses to remain ignorant ... in fear of what a little knowledge will disclose ... such selective ignorance is bad faith.” (internal quotation omitted)); see also Manitowoc II, 485 F.3d at 978 n. 5 (suggesting that “extending] credit based on documents that look[ ] suspicious” would be bad faith); Manitowoc I, 2005 WL 2460719, at *5 (“To the extent an insured’s negligence rose to the level of gross negligence or knowing indifference to red flags raised about a document or customer, the bond’s good faith requirement would preclude coverage.”); cf. Stix Friedman & Co. v. Fid. & Deposit Co. of Md., 563 S.W.2d 517, 521 (Mo.Ct.App.1978) (approving a jury instruction stating, “ ‘good faith’ means freedom from knowledge of circumstances which ought to put a person on inquiry” (emphasis added)).
citation_b.signal: cf.
citation_b.identifier: 563 S.W.2d 517, 521
citation_b.parenthetical: approving a jury instruction stating, " 'good faith' means freedom from knowledge of circumstances which ought to put a person on inquiry" (emphasis added
citation_b.sentence: See Marsh Inv. Corp. v. Langford, 721 F.2d 1011, 1014 (5th Cir.1983) (“[M]ere ignorance is not bad faith, but ... if one chooses to remain ignorant ... in fear of what a little knowledge will disclose ... such selective ignorance is bad faith.” (internal quotation omitted)); see also Manitowoc II, 485 F.3d at 978 n. 5 (suggesting that “extending] credit based on documents that look[ ] suspicious” would be bad faith); Manitowoc I, 2005 WL 2460719, at *5 (“To the extent an insured’s negligence rose to the level of gross negligence or knowing indifference to red flags raised about a document or customer, the bond’s good faith requirement would preclude coverage.”); cf. Stix Friedman & Co. v. Fid. & Deposit Co. of Md., 563 S.W.2d 517, 521 (Mo.Ct.App.1978) (approving a jury instruction stating, “ ‘good faith’ means freedom from knowledge of circumstances which ought to put a person on inquiry” (emphasis added)).