Rhone v. First American Title Insurance Company 

Plaintiffs sued title insurance company for declaration that title policy for townhome they bought in 2006 covered unassessed property taxes for 2004 and 2005. Unassessed property taxes did not constitute liens or encumbrances until bills for those unassessed taxes were issued in 2008, which was after the effective date of the title insurance policy, and were thus not covered by title policy. Plaintiffs had knowledge that townhome had been wrongly assessed as vacant land from 2004 to 2006, and could have altered proration agreement to include sellers' liability for additional taxes upon reassessment.