Meridian Title Corp. v. Pilgrim Financing, LLC, 947 N.E.2d 987

Pilgrim financed CAAP mortgages on Kerusso and Garcia; Meridian later learned of them and treated them as liens against property.
Meridian was the title/closing agent for a Northcote Avenue property refinance and an adjacent purchase; Pilgrim expected proceeds security under the CAAPs.
Petersen (Pilgrim's CEO) communicated with Meridian to obtain payoff letters and releases, while seeking to maximize proceeds for Kerusso and Garcia.
Meridian notified Pilgrim of net closing figures but disbursed $32,994.60 to Kerusso/Garcia instead of Pilgrim after sharing net figures with Petersen.
Petersen delivered the original partial release after Meridian disbursed proceeds; later, Garcia/Kerusso's actions were revealed in foreclosure proceedings.
Trial court found Meridian negligently failed to transmit Pilgrim's closing proceeds balance; judgment for Pilgrim for $32,994.60.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Meridian negligently disburse closing proceeds?	Pilgrim contends Meridian owed a duty and breached it by improper disbursement.	Meridian argues no duty to Pilgrim; the escrow-like relationship not established or the breach not proven.	Yes; Meridian negligently disbursed the proceeds.

Yost v. Miller, 129 N.E.2d 487 (Ind. 1921) (escrow concepts without formal agreement possible)
Freeland v. Charnley, 80 Ind. 132 (Ind. 1881) (escrow-like delivery can create obligations)
Moslander v. Beldon, 164 N.E.277 (Ind. App. 1928) (escrow implied without formal agreement)
In re Marriage of Glendenning, 684 N.E.2d 1175 (Ind. Ct. App. 1997) (escrow holder owes dual fiduciary duties to both parties)
Tew v. Tew, 924 N.E.2d 1262 (Ind. Ct. App. 2010) (standard of review for findings with special findings of fact)
Rider v. McCamment, 938 N.E.2d 262 (Ind. Ct. App. 2010) (negligence elements and duty considerations)
Schrader v. Porter Cnty. Drainage Bd., 880 N.E.2d 304 (Ind. Ct. App. 2008) (two-tier standard of review for special findings)