An escrow company owes no duty of care to a person who is neither party to the escrow nor a third party beneficiary. An escrow company owes no duty of care to a person who is not a party to the escrow and is not named in the escrow documents as a third party beneficiary, particularly when the person’s losses due not result directly from the escrow company’s negligence.
California Court of Appeals, Third District (Hoch, J.); November 16, 2016 (published December 9, 2016); 6 Cal. App. 5th 551