LOS ANGLES - A California appeals panel on Jan. 21 ruled that because a trustee was not a party to a title insurance policy in his individual capacity, he was able to bring claims against the insurer only in his capacity as a trustee, not individually (Bruce T. Mulhearn, et al. v. Lawyers Title Insurance Co., et al., No. B244893, Calif. App., 2nd Dist.; 2014 Cal. App. Unpub. LEXIS 373).