Cal. Ct. App. 1st Dist. · Court of Appeal opinion · January 1, 2021
Related by Seller ProceedsCourt record Court of Appeal opinion
Akin v. Business Title — California Court of Appeal
California Court of Appeal, First District, Division One · 264 Cal.App.2d 153
AmountNot statedAmount not stated in reviewed source.
ResultCourt of Appeal opinionCourt ruling
HingeSeller ProceedsTeaches exculpatory escrow clauses do not bar recovery when the holder willfully departs from instructions — including geographic recordation errors after close.
SourceCourt opinionPublished opinion
File-record question
Teaches exculpatory escrow clauses do not bar recovery when the holder willfully departs from instructions — including geographic recordation errors after close.
Limit before takeaway
Published appellate opinion only. Lee v. Title Ins. & Trust Co. (1968) 264 Cal.App.2d 160 (supporting link) on limited duty to police unrelated suspicious facts.
- Court / region
- Cal. Ct. App. 1st Dist.
- Case number
- 264 Cal.App.2d 153
- Filed
- January 1, 1968
- 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 a broad exculpatory clause in an escrow agreement cannot shield an escrow holder from liability for its own willful breach, including recording a deed of trust in the wrong county after escrow closed.
What it hinged on
Seller Proceeds. Teaches exculpatory escrow clauses do not bar recovery when the holder willfully departs from instructions — including geographic recordation errors after close.
Amount involved
Amount not stated in reviewed source.
Result
Court of Appeal opinion
Why this belongs here
Teaches exculpatory escrow clauses do not bar recovery when the holder willfully departs from instructions — including geographic recordation errors after close.
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 exculpatory escrow clauses do not bar recovery when the holder willfully departs from instructions — including geographic recordation errors after close.
Timeline
FiledJanuary 1, 1968
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
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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. Lee v. Title Ins. & Trust Co. (1968) 264 Cal.App.2d 160 (supporting link) on limited duty to police unrelated suspicious facts.
Reviewed California court records with source links. Allegations are not findings.