Fifth Circuit Questions Texas Residency Rule for Escrow Officers
August 25, 2026
A recent decision from the U.S. Court of Appeals for the Fifth Circuit could have significant implications for title and settlement professionals seeking to work across state lines. In Polk v. Crawford, the court ruled that Texas likely violated the U.S. Constitution by denying an escrow officer license to an otherwise qualified applicant solely because he did not live in Texas or a state bordering Texas. The Aug. 4 opinion reverses a lower court's denial of a preliminary injunction and directs the district court to prohibit enforcement of the residency requirement against the plaintiff while the case proceeds.
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