Wilmot v. First American Title Co. CA2/5

CourtCalifornia Court of Appeal
DecidedMay 2, 2025
DocketB322298
StatusUnpublished

This text of Wilmot v. First American Title Co. CA2/5 (Wilmot v. First American Title Co. CA2/5) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wilmot v. First American Title Co. CA2/5, (Cal. Ct. App. 2025).

Opinion

Filed 5/2/25 Wilmot v. First American Title Co. CA2/5 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION FIVE

ELIZABETH WILMOT, B322298

Plaintiff and Appellant, (Los Angeles County Super. Ct. Nos. v. JCCP4751, BC370141) FIRST AMERICAN TITLE CO.,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County, Maren E. Nelson, Judge. Reversed and remanded. Shernoff Bidart Echeverria and Michael J. Bidart; Gupta Wessler, Deepak Gupta, Gregory A. Beck, Robert D. Friedman, Ameze Belo-Osagie, and Jennifer D. Bennett; Freidman & Rubin and Richard H. Friedman; The Bernheim Law Firm and Steven J. Bernheim for Plaintiff and Appellant. Dentons US, Ronald D. Kent, Joel D. Siegel, Gary Roberts, and Doug Janicik for Defendant and Respondent. First American Title Company (FATCO) served as plaintiff and appellant Elizabeth Wilmot’s (Wilmot’s) escrow agent for a real property purchase in 2004.1 Years later, Wilmot sued FATCO asserting various causes of action all with the same gist: FATCO improperly charged her a $125 loan tie-in fee that was unauthorized because FATCO had not duly filed the rate with the Department of Insurance. After multiple rounds of demurrers—the last of which was partially granted—Wilmot elected to dismiss her remaining claims to appeal the trial court’s decision sustaining FATCO’s demurrer as to her causes of action for breach of contract, breach of the covenant of good faith and fair dealing, breach of fiduciary duty, negligence, unjust enrichment, and money had and received. We consider whether the operative complaint sufficiently alleges any of these claims even though the property purchase agreement and escrow instructions were not attached to any of the complaints or recited verbatim in the complaints themselves.

1 Though Wilmot named three First American entities as defendants in her earlier complaints (First American Title Company, First American Title Insurance Company, and First American Corporation), only FATCO remained a defendant as of the last iteration of the complaint, and Wilmot does not challenge the dismissal of the other First American entities on appeal. As a result, we describe the allegations as they pertain to FATCO only.

2 I. BACKGROUND A. Background Facts Wilmot purchased a home in Moreno Valley, California in or around 2004. FATCO served as the escrow agent for Wilmot’s transaction. FATCO is a controlled escrow company and required to file a schedule of rates with the Department of Insurance for all services it performs. FATCO’s schedule of rates in effect at the relevant time did not include a rate for a loan tie-in fee. FATCO nevertheless charged Wilmot a $125 loan-tie in fee in connection with her home purchase.2 Wilmot did not discover facts relating to the charging of what she would later contend was the improper loan tie-in fee until or about March 2007, when she attended a social event and met an attorney who mentioned FATCO when discussing the types of cases he was handling.

B. The Initial Iterations of the Complaint 1. Original and first amended Wilmot and her co-plaintiff Jason Munro’s original complaint, filed in April 2007, alleged ten causes of action on behalf of themselves and a putative class.3 A first amended complaint was filed later the same year. The first amended complaint alleged causes of action for breach of contract, breach of the implied covenant of good faith and fair dealing, breach of

2 FATCO did not have a filed rate for a loan tie-in fee until February or March 2007. 3 Munro, who was a named plaintiff through the Fourth Amended Complaint, was not a named plaintiff in the Fifth Amended Complaint and is not a party to this appeal.

3 fiduciary duty, negligence, fraud, constructive fraud, unjust enrichment, violation of the Consumer Legal Remedies Act (CLRA), violation of the Unfair Competition Law (UCL), and declaratory relief. FATCO demurred to all ten causes of action and argued, among other things, that Wilmot had not sufficiently alleged her breach of contract claims because the complaint did not adequately describe the terms of any written contract or the ways in which the contract was allegedly breached. The trial court sustained the demurrer with leave to amend as to all but Wilmot’s cause of action for fraud.

2. Second amended The subsequently filed Second Amended Complaint (SAC) alleged nine causes of action: breach of contract, breach of the implied covenant of good faith and fair dealing, breach of fiduciary duty, negligence, fraud, constructive fraud, restitution, violation of the CLRA, and violation of the UCL and the False Advertising Law (FAL). The breach of contract claim (which figures prominently in this appeal) alleged Wilmot and putative class members entered into a contract with FATCO pursuant to which FATCO “promised to provide escrow services and title insurance to plaintiffs and . . . to their lenders.” Wilmot alleged the contract was written or, in the alternative, implied-in-fact. As to the alleged written contract, she alleged it was “evidenced by documents such as: (a) the Residential Purchase Agreement [a]nd Joint Escrow Instructions dated January 8, 2004, providing that the buyer (Wilmot) and the seller shall each pay their own escrow fee; (b) the Supplemental Escrow Instructions thereto, dated January 13,

4 2004 . . . providing that ‘Upon Close of Escrow, Escrow Holder is instructed to disburse in accordance with the executed “Estimated Settlement” Statement without further instruction from the parties thereto’; (c) the ‘Escrow General Instructions’ incorporated by reference into the Supplemental Escrow Instructions; (d) the letter dated January 13, 2004 to Wilmot from Jean O’Neill ‘Escrow Officer’ for ‘First American Title Company,’ stating among other things that ‘First American Title Company will be handling your transaction . . .’ and purporting to enclose among other things ‘General Provisions for First American [T]itle Company’; (e) the letter dated January 12, 2004, transmitting the Supplemental Escrow Instructions from Jean O’Neill . . . to Wilmot’s agent, and stating among other things ‘Thank you for selecting First American Title Company to process your escrow. We have accepted the agency obligation as Escrow holder and look forward to working with you towards a smooth closing’; (f) the Buyer’s Estimated Settlement Statement . . . estimating an ‘Escrow Fee’ to be paid to ‘First American Title Company’ in the amount of $125 . . .’; (g) the Estimated Settlement Statement purportedly prepared by ‘First American Title Company’ showing the same information . . . as . . . shown on the Buyer’s Estimated Settlement Statement; and (h) the HUD-1 Settlement Statement . . . representing under the section for ‘Title Charges’ on line 1113 a ‘Loan Tie In Fee to First American Title Company’ in the amount of $125; and (e) receipts in the name of ‘First American Title Company’ for deposits of earnest money deposit, loan proceeds, and additional closing costs.” Wilmot alleged the referenced documents “identify [FATCO] as the escrow agent and therefore the party to the contract . . . .”

5 Wilmot also alleged in the alternative that the agreement was implied from the conduct, situation, or mutual relation of the parties, and that FATCO promised to act and acted as the escrow company.

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Wilmot v. First American Title Co. CA2/5, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilmot-v-first-american-title-co-ca25-calctapp-2025.