In Fidelity National Title Ins. Co. of New York v. OHIC Ins. Co., Nos. A05A1179, A05A1180, 2005 WL 1792197 (Ga. App. July 29, 2005), a Georgia appeals court held that a title insurance company's claims against an attorney “arose out of the conversion, misappropriation, and commingling of client funds.”

Renee Snead was an attorney who conducted real estate closings and was an approved attorney for Fidelity National Title Insurance Company. She carried professional liability insurance through OHIC Insurance Company.