Cal. Ct. App. 1st Dist. · Court of Appeal opinion · January 1, 2021
Related by Seller ProceedsCourt record Court of Appeal opinion
Roberts v. Carter & Potruch — California Court of Appeal
California Court of Appeal, Second District, Division Three · Civ. No. 21393
AmountNot statedAmount not stated in reviewed source.
ResultCourt of Appeal opinionCourt ruling
HingeSeller ProceedsTeaches escrow holders are agents, not parties, to the underlying sale contract — and that post-close payment duties with oral instructions face short limitations windows.
SourceCourt opinionPublished opinion
File-record question
Teaches escrow holders are agents, not parties, to the underlying sale contract — and that post-close payment duties with oral instructions face short limitations windows.
Limit before takeaway
Published Court of Appeal opinion only. Amen v. Merced County Title Co. (1962) 58 Cal.2d 528 (supporting link) later disapproved this limitations framework for written escrow instructions.
- Court / region
- Cal. Ct. App. 2d Dist.
- Case number
- Civ. No. 21393
- Filed
- January 1, 1956
- 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 attorney-escrow holder that received installment payments after closing was not a party to the underlying written sale contract, and the two-year limitations period barred recovery for failing to remit those payments.
What it hinged on
Seller Proceeds. Teaches escrow holders are agents, not parties, to the underlying sale contract — and that post-close payment duties with oral instructions face short limitations windows.
Amount involved
Amount not stated in reviewed source.
Result
Court of Appeal opinion
Why this belongs here
Teaches escrow holders are agents, not parties, to the underlying sale contract — and that post-close payment duties with oral instructions face short limitations windows.
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 agents, not parties, to the underlying sale contract — and that post-close payment duties with oral instructions face short limitations windows.
Timeline
FiledJanuary 1, 1956
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 Court of Appeal opinion only. Amen v. Merced County Title Co. (1962) 58 Cal.2d 528 (supporting link) later disapproved this limitations framework for written escrow instructions.
Reviewed California court records with source links. Allegations are not findings.