With no explanation, chose the best option from "A", "B", "C" or "D". Co. v. Kountz, 461 So.2d 802, 810 (Ala.1984), where he expressed concern that indiscriminate references to recklessness might cause .confusion that could lead to the imposition of liability for bad faith without proof of an intentional injury. 5 . Compare the reference to "rare and extreme cases” in Waldon v. Cotton States Mutual Insurance Co., 481 So.2d 340, 341 (Ala.1985), with the observation in United Insurance Co. of America v. Cope, 630 So.2d 407, 412 (Ala.1993), that rarity of bad-faith claims has not been the experience. 6 . We will not parse the record for evidence of mental anguish in an attempt to reduce the ratio between compensatory and punitive damages when the jury has not awarded damages for such harm. Compare Life Ins. Co. of Georgia v. Smith, 719 So.2d 797 (Ala.1998) (<HOLDING>). * Note from the reporter of decisions: On

A: holding that conduct must be beyond the fraud which supported compensatory damages to award punitive damages
B: holding that when compensatory damages are nominal a much higher ratio of punitive damages to compensatory damages can be contemplated
C: holding that a plaintiff who proves a cause of action under  1981 may recover punitive damages where the plaintiff is entitled to an award of compensatory damages even if nominal
D: holding that the court will not parse the record for evidence of compensatory or nominal damage to justify an award of punitive damages only
D.