PHILADELPHIA - Although a Third Circuit U.S. Court of Appeals panel on June 17 found that a genuine dispute existed over whether a title insurer breached its contract by delaying a quiet title proceeding on its insureds' behalf, the panel held that delay due to corporate restructuring might constitute negligence or mistake but not bad faith (Bryan Granelli, et al. v. Chicago Title Insurance Co., et al., No. 13-1024, 3rd Cir.; 2014 U.S. App. LEXIS 11235).