Equity Income Partners, LP v. Chicago Title Insurance Co.

JUDGE BARTON,

opinion of the Court:

¶ 1 The United States Court of Appeals for the Ninth Circuit was recently asked to decide what impact, if any, a lender’s full-credit bid made at an Arizona trustee’s sale has on an insurer’s liability under standard form title insurance policies. See Equity Income Partners, LP v. Chi Title Ins. Co., 828 F.3d 1040, 1040 (9th Cir. 2016) (mem.). The policy provisions at issue are Sections 2, 7 and 9, which are quoted in full below. Briefly, Section 2 provides that coverage continues in force when an insured acquires the property in a foreclosure sale, but the…