Cal. Ct. App. 1st Dist. · Court of Appeal opinion · January 1, 2021
Related by Seller ProceedsCourt record Court of Appeal opinion
Howard v. Security Title — California Court of Appeal
California Court of Appeal, Fourth District · Civ. No. 1794
AmountNot statedAmount not stated in reviewed source.
ResultCourt of Appeal opinionCourt ruling
HingeSeller ProceedsDistinguishes written buyer-seller escrow instructions from the holder's separate parol agency duty — background for Amen's later four-year written-contract rule and Simmons exculpatory clauses.
SourceCourt opinionPublished opinion
File-record question
Distinguishes written buyer-seller escrow instructions from the holder's separate parol agency duty — background for Amen's later four-year written-contract rule and Simmons exculpatory clauses.
Limit before takeaway
Published Court of Appeal opinion only. Gallagher v. California Pac. T. & T. Co. (1936) 13 Cal.App.2d 482 (supporting link) involved a holder that undertook written payment duties.
- Court / region
- Cal. Ct. App. 4th Dist.
- Case number
- Civ. No. 1794
- Filed
- January 1, 1937
- 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 action against an escrow holder for closing a property exchange without securing a canceled lease assignment was subject to the two-year limitations period because liability rested on an implied parol agency agreement, not on the written escrow instructions alone.
What it hinged on
Seller Proceeds. Distinguishes written buyer-seller escrow instructions from the holder's separate parol agency duty — background for Amen's later four-year written-contract rule and Simmons exculpatory clauses.
Amount involved
Amount not stated in reviewed source.
Result
Court of Appeal opinion
Why this belongs here
Distinguishes written buyer-seller escrow instructions from the holder's separate parol agency duty — background for Amen's later four-year written-contract rule and Simmons exculpatory clauses.
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:
Distinguishes written buyer-seller escrow instructions from the holder's separate parol agency duty — background for Amen's later four-year written-contract rule and Simmons exculpatory clauses.
Timeline
FiledJanuary 1, 1937
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.
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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. Gallagher v. California Pac. T. & T. Co. (1936) 13 Cal.App.2d 482 (supporting link) involved a holder that undertook written payment duties.
Reviewed California court records with source links. Allegations are not findings.