Seeley

In these consolidated actions for slander of title and negligence in connection with the recordation of a purported “Memorandum of Agreement” to lease plaintiff’s property, a jury awarded plaintiff and respondent Richard Seeley (Seeley) $200,000 in compensatory damages jointly and severally against defendants-appellants Bruce A. Seymour (Seymour), Safeco Title Insurance Company (Safeco) and defendants City and County of San Francisco and its recorder Thomas Kearney (the City). The jury also awarded Seeley $2.66 million punitive damages against Seymour. Only Seymour and Safeco appeal from the ensuing judgment.

Background

The facts of this case are largely undisputed. We summarize the essential ones.

In 1972, Richard Seeley acquired an unimproved lot located at Washington and Battery streets in the downtown area of San Francisco. He bought the lot from the City at an auction for $97,000. Over the next 10 years, Seeley received many inquiries and offers to purchase the property, none of which culminated in a sale.

In early 1978, Seymour, through his broker Bill Graham, submitted a written offer to purchase the property for $250,000. Seeley rejected the offer, but…