J. H. Trisdale, Inc. v. Shasta etc. Title Co

In J. H. Trisdale, Inc. v. Shasta etc. Title Co. (1956) 146 Cal.App. 2d 831, a title insurer misidentified the holder of an easement in a preliminary title report and in a title insurance policy. The court considered the preliminary title report to be the equivalent of an abstract of title, and upheld liability for misidentification--the easement holder was misidentified as Pacific Telephone and Telegraph Company, whereas in fact the easement belonged to the Pacific Gas and Electric Company. (J. H. Trisdale, supra, 146 Cal. App. 2d at pp. 835, 837-838.) The court also held that by misidentifying the holder of the easement, the insurer had breached the title insurance policy. (Id. at pp. 835-836.)