Cal. Ct. App. 1st Dist. · Court of Appeal opinion · January 1, 2021
Related by Seller ProceedsColonial Savings v. Redwood Empire Title — California Court of Appeal
California Court of Appeal · Civ. No. 22259
Contrasts definite written escrow instructions with ambiguous ones — when a lender tells the holder exactly which exceptions to allow, the holder is not liable for liens the instructions left in place.
Published Court of Appeal opinion only. Spaziani v. Millar (1963) 215 Cal.App.2d 667 (supporting link) discusses indefinite escrow instructions where a nonsuit was improper.
- Court / region
- Cal. Ct. App.
- Case number
- Civ. No. 22259
- Filed
- January 1, 1965
- 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 the title company followed the lender's express written escrow instructions when issuing policies that did not except assessment liens the lender had not required be paid or excluded, and any loss flowed from the lender's instructions rather than the holder's breach.
What it hinged on
Amount involved
Amount not stated in reviewed source.
Result
Court of Appeal opinion
Why this belongs here
Contrasts definite written escrow instructions with ambiguous ones — when a lender tells the holder exactly which exceptions to allow, the holder is not liable for liens the instructions left in place.
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:
Timeline
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.
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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 Court of Appeal opinion only. Spaziani v. Millar (1963) 215 Cal.App.2d 667 (supporting link) discusses indefinite escrow instructions where a nonsuit was improper.