GEORGE M. SONNETT, JR. and WENDY Z. BURGERS SONNETT, Husband and Wife, Appellants (Plaintiffs), v. FIRST AMERICAN TITLE INSURANCE COMPANY, a California corporation, and FIRST AMERICAN TITLE INSURANCE COMPANY OF SUBLETTE COUNTY, a Wyoming corporation, Appellees (Defendants)., 2013 WY 106

HOLDINGS: [1]-Because a plan created by previous owners to gain approval for a zoning change was not a set of restrictive covenants or an encumbrance upon title, there was no coverage under a title insurance policy excluding governmental regulations restricting land use and specifically excluding any loss or damages related to a zoning resolution that had been amended in accordance with the plan; [2]-The insurer was entitled to summary judgment on a bad faith claim because there was a reasonable basis for its denial of coverage and the record did not support the insureds' allegation that it had conducted a deficient investigation; [3]-The issuance of title commitments provided no basis for negligence claims because a report issued by a title insurer was not an abstract of title, as stated in Wyo. Stat. Ann. § 26-23-303(a)(xvii), and did not give rise to an abstractor's duty of care.