You Get What You Pay For: Title Insurers Need Only Defend Claims Explicitly Covered in Policy

On November 13, the Seventh Circuit Court of Appeals decided in a case of first impression that the “complete defense” rule does not apply to title insurers and overturned the Northern District of Illinois’s ruling in Philadelphia Indemnity Ins. Co. v. Chicago Title Ins. Co. that defendant Chicago Title could not limit the defense of its insured to claims that might arise under the subject title insurance policy. In 2007, Western Capital Partners, LLC, a high-risk real estate lender, moved
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