The Georgia Court of Appeals recently reversed the grant of summary judgment to a defendant on the issue of bad faith attorney’s fees. Nash v. Reed, A18A1707, 2019 WL 1123530 (Ga. Ct. App. Mar. 12, 2019). In so doing, the court determined that “[b]ad faith under OCGA § 13-6-11 must have arisen out of how the defendant acted in dealing with the plaintiff.” In Nash, the plaintiff was struck by the defendant’s automobile while jogging. The defendant saw the plaintiff, knew th