Snow et al v. First American Title Insurance Company

Chenault et al. v. Mississippi Valley Title Insurance Company and Old Republic National Title Insurance Company (cases consolidated on appeal)
The underlying cases involved allegations that RESPA's anti-kickback and fee-splitting provisions were violated by title insurance companies whose compensation plans rewarded agents for generating high volumes of sales. The plaintiff alleged that the agents who sold them title insurance received additional compensation in violation of the RESPA provisions.

The appeal involved the issue of when RESPA's statute of limitations begins to run.

Both suits were filed more than one year after the plaintiffs' real estate closings and the defendants argued that the claims arose at closing and were barred by RESPA's one-year statute of limitations. The district courts agreed and entered judgment for the defendants. The plaintiffs appealed. The cases were consolidated on appeal to the 5th Circuit U.S. Court of Appeals.

On appeal, the plaintiffs acknowledged the applicability of the one year statute of limitations but argued the time started running not at closing, but when the agents received the additional compensation.

The 5th Circuit Court held that the one year statute of limitations started running at closing and affirmed the decision of the lower courts.