Cal. Ct. App. 1st Dist. · Court of Appeal opinion · January 1, 2021
Related by Seller ProceedsCourt record Court of Appeal opinion
Hannon v. Western Title — California Court of Appeal
California Court of Appeal, Second District, Division Five · 211 Cal.App.3d 1122
AmountNot statedAmount not stated in reviewed source.
ResultCourt of Appeal opinionCourt ruling
HingeSeller ProceedsTeaches escrow holders are limited agents who must follow instructions — they are not trustees required to invest idle escrow balances unless the parties contract for interest.
SourceCourt opinionPublished opinion
File-record question
Teaches escrow holders are limited agents who must follow instructions — they are not trustees required to invest idle escrow balances unless the parties contract for interest.
Limit before takeaway
Published appellate opinion only. Schaefer v. Manufacturers Bank (1980) 104 Cal.App.3d 70 (supporting link) on limited agency duties.
- Court / region
- Cal. Ct. App. 2d Dist.
- Case number
- 211 Cal.App.3d 1122
- Filed
- January 1, 1989
- Source record
- Court opinion
- Procedural posture
- Court of Appeal opinion
- Money movement stage
- Seller proceeds stage
- Record gap
- Payee gap
- Strongest reviewed source
- Published opinion
- Allegation / finding status
- Court ruling
- Disposition
- Court of Appeal opinion
- Last posture checked
- 2026-05-31
- Reviewed
- 2026-05-31
What happened
Court held an escrow holder has no common-law duty to deposit escrow funds in an interest-bearing account absent express instructions to do so.
What it hinged on
Seller Proceeds. Teaches escrow holders are limited agents who must follow instructions — they are not trustees required to invest idle escrow balances unless the parties contract for interest.
Amount involved
Amount not stated in reviewed source.
Result
Court of Appeal opinion
Why this belongs here
Teaches escrow holders are limited agents who must follow instructions — they are not trustees required to invest idle escrow balances unless the parties contract for interest.
Documents to inspect
- Seller instructions
- Authorization request
- Callback log
- Wire confirmation
- Closing statement
- Escrow instructions
This list is inferred from the topic pattern, not asserted as an extracted document list for this case.
What the file needed to show
Current reviewed metadata frames the file issue this way:
Teaches escrow holders are limited agents who must follow instructions — they are not trustees required to invest idle escrow balances unless the parties contract for interest.
Timeline
FiledJanuary 1, 1989
Posture checked2026-05-31
Reviewed for Escrow Cases2026-05-31
Topics
Related patterns
Related records are selected from shared topics, hinge category, court type, and posture. They are discovery aids, not claims that the facts or results match.
Continue research
Open a related reviewed-record search or save this trail when the file-record question is worth revisiting.
Source record
What this record does not show
This reviewed record does not show a court finding that any company or person did anything wrong unless the linked source expressly says so. Read the primary source for allegations, posture, and outcome.
Limit: Published appellate opinion only. Schaefer v. Manufacturers Bank (1980) 104 Cal.App.3d 70 (supporting link) on limited agency duties.
Reviewed California court records with source links. Allegations are not findings.