Zions First National Bank, N.a., Plaintiff and Respondent v. National American Title Insurance Company, Defendant…

Summary

The Utah Supreme Court affirmed the trial court’s judgment that National American Title Insurance must pay Zions for the forged‑deed loss, reversed the award of attorney fees earned in suing the insurer, and remanded for determination of fees related to defending a third‑party quiet‑title action. The court held that the policy did not require Zions to inquire about the signatures, that Zions lacked actual or constructive knowledge of the forgery, that Zions substantially complied with the proof‑of‑loss provision, and that the fee award for the suit against the insurer was unsupported.