Ryczkowski v. Chelsea Title & Guaranty Co.

J.J. Cleary contracted to buy Nevada land in 1946 but didn't acquire title until 1952, and the unrecorded land-sale contract meant Cleary lacked record title in 1949 when he granted a power line easement to Sierra Pacific Power Company, which was recorded that year despite Cleary not yet holding title. Title later passed through several owners until Ryczkowski (plaintiff) acquired it in 1964, after engaging Title Guaranty to search for title defects (a search that only went back to 1952, when Cleary acquired title, and never uncovered the 1949 easement) and contracting with Chelsea Title & Guaranty Co. (Chelsea Title) (defendant) to insure title. Ryczkowski sued Chelsea Title after discovering the easement (Title Guaranty having gone out of business), and the trial court entered judgment for Chelsea Title, finding it could not be held liable.