Creason v. Peterson
In Creason v. Peterson, 24 Utah 2d 305, 307, 470 P.2d 403 (1970), the Court held that the damages recoverable for breach of the covenants of seisin and the right to convey were limited in that case. 24 Utah 2d at 307, 470 P.2d at 404.
Specifically, the Court held that the plaintiff could recover only damages actually resulting from the breach, which included "reasonable and necessary" costs incurred "to clear up any difficulty that would represent a substantial flaw in his title," such as reasonable attorney fees. Id. at 307-09, 470 P.2d at 404-05.