Rattikin Title Co. and the Unauthorized Practice of Law: Limits on Title Company Document Preparation in Oil & Gas Transactions

The Fort Worth Court of Civil Appeals affirmed a temporary injunction against Rattikin Title Company, holding that when the title company prepared legal instruments for third parties in transactions where it had no interest and gave advice regarding the purpose and effect of legal instruments to non-principals, it engaged in the unauthorized practice of law. The court distinguished permissible activities performed for the title company's principal, Kansas City Title Insurance Company, from impermissible legal services provided to third parties for consideration.