Rechtzigel v. Fidelity National Title Insurance Company of New York, 748 N.W. 2d 312 (Minn. Ct. App. 2008)

(title insurance does not cover monetary losses incurred by insured arising out of bankruptcy of qualified intermediary used in I.R.C. §1031 exchange absent claims asserting threat to marketability of title; thus, unless bankruptcy trustee’s preference action against insured does not implicate marketability of title or other risks specified in policy, title insurer has no duty to defend under policy).