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4 lawsuits, 4 lessons in Notary liability

A gavel representing the authority of the court and scales representing the weighing of evidence and pursuit of justice.

Updated 2-26-24.  Being sued over a notarization is painful for any Notary and costly in time, stress and legal fees. And sometimes Notaries are sued even when they aren't at fault. 

Merchants Bonding Company, the carrier for NNA bonds and insurance policies, recently shared a number of Notary claims with the Notary Bulletin. These claims provide important lessons about protecting yourself from financial liability resulting from the notarizations you perform.

The case of the stubborn plaintiff

In this case, a Notary was asked to visit a hospital and notarize a power of attorney document. The document granted the signer’s friend the right to handle his medical and legal affairs while he was hospitalized. The signer later filed a lawsuit against the Notary, claiming he was not aware of what he was signing.

During the case, the plaintiff was declared a “vexatious litigant” by the court after it was learned he had a history of filing frivolous lawsuits. The Notary’s attorney claimed the grounds for the suit were legally insufficient and the court upheld this claim.

But, the plaintiff didn’t stop. He filed a second suit against the Notary and several other defendants a year later. Eventually, the second case was settled, but not until the Notary incurred additional attorney fees in responding to the new allegations.

Notary Liability Lesson 1:

This case teaches an important lesson. Litigation can get messy, and sometimes litigants don’t give up. As a result, you can incur significant costs in defending yourself — even against frivolous claims. In this instance, the Notary had an errors and omissions insurance policy, and it took a substantial amount of the policy to defend the Notary in both actions. Without a policy with sufficient coverage to absorb all the costs, he would have had to pay the expenses out of his own pocket.

The case of the Notary caught in the crossfire

Some Notaries assume that they don’t have to carry an E&O policy as long as they don’t make mistakes. As this next case shows, even a blameless Notary can be dragged into a lawsuit.

In this situation, the Notary was among several individuals sued for more than $200,000 over a real estate transaction. The litigant claimed the Notary had failed to properly check a signer’s identity during the transaction. Later investigation acquitted the Notary of all wrongdoing.

However, the lawsuit proved extremely difficult — and costly — to resolve because of the multiple complaints and cross-complaints involving the numerous defendants.

Notary Liability Lesson 2:

Your financial risk as a Notary often has nothing to do with being right. You can be right and still end up with legal bills. Fortunately, the Notary’s E&O policy in this case paid the legal expenses.

The case of the costly thumbprint

In this case, an oversight when recording a journal entry got a Notary into serious legal trouble. During a notarization involving real property, the Notary was distracted and failed to take the signer’s thumbprint for her journal entry as required by state law. It was later discovered that the signer was an impostor, and the Notary was sued for $250,000.

Notary Liability Lesson 3:

After lengthy negotiations, the case was eventually settled, but the Notary’s full E&O policy was exhausted. The lesson here is that E&O insurance will cover claims up to their policy's limit when Notaries are clearly negligent, as in this case where the Notary forgot to obtain the signer’s thumbprint in the journal entry. It happens; people make mistakes. Even good Notaries make mistakes.

The case of multiple mistakes

As bad as it is for a Notary to be sued after following proper procedure, the situation can be even worse if the Notary ignores state rules when verifying a signer’s identity.

In this case, the Notary was asked to notarize the signatures of two individuals who signed a deed of trust in buying a property. Since the signers had no ID, the Notary identified them using a single credible identifying witness — the agent representing the signers. State law required the Notary to personally know the witness, but the Notary hardly knew the agent. In addition, the Notary failed to obtain the thumbprints of the signers in her journal. The settlement and legal fees were substantial.

Notary Liability Lesson 4:

By ignoring the rules for identifying signers and obtaining thumbprints, the defendant in this case not only faced a costly lawsuit but left the transaction vulnerable to potential fraud. In fact, a handwriting expert indicated that it was “highly probable” the signatures notarized on the deed of trust in question were forged. Fortunately for the Notary, the E&O policy covered multiple mistakes in the same claim, which is true of many policies as long as the violations aren’t intentional.

E&O insurance helps cover legal costs for Notaries

You also should be aware that you could be caught up in a legal action even if you are not named in a lawsuit. There have been several situations in which Notaries have received subpoenas for information about a notarization they performed. Subpoenas included requests for Notary journal entries or affidavits or a demand to appear at a deposition to provide information about a past notarization.

If you are served with a subpoena, an E&O policy that covers attorney costs helps make sure you'll have a lawyer's legal guidance when responding to the subpoena. It also helps you avoid being named in the lawsuit, and aids in covering legal fees.  

Conclusions about Notary lawsuits

Following your state’s laws and best practices will take you far in protecting your Notary practice from legal action. But it won’t take you all the way. For the last mile, you’ll need an errors and omissions insurance policy. While Notary bond and insurance claims are infrequent, no Notary is immune to liability. You can make a mistake that financially harms a signer. You can do everything right and still end up in court. You can face litigious plaintiffs who will try more than once to find you at fault and make you pay. The good news is that, for all of these reasons, there’s Notary E&O insurance.

David Thun is the Editorial Manager at the National Notary Association.


Related Articles:

10 steps Notaries can take to avoid being sued


Additional Resources:

Differences Between E&O Insurance and Surety Bonds

Notary Lawsuit Protection


View All: Best Practices

52 Comments

Add your comment

Cheryl

01 Feb 2024

I have a serious question . I believe that my father's will was not legal. Upon research I feel that the notary stamp was not legal... What can I do .

National Notary Association

01 Feb 2024

Hello. You will need to contact a qualified attorney for any legal advice regarding the legality of the will and your options.

vegasdiva0@gmail.com

20 Sep 2023

I am a notary in Las Vegas, NV. I have been requested to sign a tourist signing for a Florida property, The title company insists that I provide the witnesses. But the NV law states the witness must be known by the signer and the notary. How do I accomplish this? Not just here, but anywhere. Seems impossible for witness to be known by signer and notary.

National Notary Association

28 Sep 2023

Based on what you’ve described, we think it would be best if you contacted our Hotline team by phone and provided them with a more detailed description of the situation. The NNA Hotline: 1-888-876-0827 Mon – Fri: 5:00 a.m. – 7:00 p.m. (PT) Saturday: 5:00 a.m. – 5:00 p.m. (PT) If you’re not an NNA Member or Hotline Subscriber, they will provide you with a one-time courtesy call.

Elton Burrus

19 Jul 2023

Does E&O insurance cover the cost of an attorney?

National Notary Association

21 Jul 2023

Hello. You would need to contact the policy issuer for details on specific coverage in individual policies.

Cheryl Wasson

24 Apr 2023

Does Michigan require a thumbprint and journal?

National Notary Association

26 Apr 2023

Hello. Michigan only requires a journal for Notaries who perform remote notarizations. A thumbprint is not required for the journal entry.

Tiffany Boney

27 Mar 2023

The state of NJ requires credible witnesses to be personally known by the Notary. If a signer does not have a valid ID but a witness, whom you do not personally know, that knows the signer is present at the time of the notarization, can you notarize the documents for the signer?

National Notary Association

28 Mar 2023

Hello. No, you may not notarize in this situation. As you mentioned in your question, NJ requires any credible identifying witness used to identify a signer to personally know the Notary.

Marisela

26 Feb 2023

A notary signed a Q.C.D without me present. Please advice . What can I do?

National Notary Association

27 Feb 2023

Based on what you’ve described, we think it would be best if you contacted our Hotline team by phone and provided them with a more detailed description of the situation. The NNA Hotline: 1-888-876-0827 Mon – Fri: 5:00 a.m. – 7:00 p.m. (PT) Saturday: 5:00 a.m. – 5:00 p.m. (PT) If you’re not an NNA Member or Hotline Subscriber, they will provide you with a one-time courtesy call.

Lynn Collins

09 Nov 2022

If you employer has a notary completes the individual acknowledgment on a deed and you are asked by your employer to notarize the affidavit of consideration for multiple Lenders that are not signed in your presence. Is this ok since they are employed by the same company as you?

National Notary Association

09 Nov 2022

Based on what you’ve described, we think it would be best if you contacted our Hotline team by phone and provided them with a more detailed description of the situation. The NNA Hotline: 1-888-876-0827 Mon – Fri: 5:00 a.m. – 7:00 p.m. (PT) Saturday: 5:00 a.m. – 5:00 p.m. (PT) If you’re not an NNA Member or Hotline Subscriber, they will provide you with a one-time courtesy call.

frederick pugh

27 Sep 2022

Any published case sites relevant to the dictates herein?!

Deirdre A. Martin

19 Jan 2022

I have several unidentified Notarys by B.Scott Everett FL. No commission ID or contact. "AKA" Bryers Everett, Bryers Scott, Scott Bryers. Most recent notary shows B Scott Everett # EE867022 area code (407) this information is not available, the phone and Notarty stamps are unavailable

Joseph Congine

12 May 2021

A renter of mine wanted to do a rent to own contract . After 2 years she had missed payments and failed to get financing . Come to find out she was a very good con. I finally evicted her and put the house on the market since there was very little owed and had past bills i need paid . Found a buyer agreed on a cash deal was getting ready to close and Bam! Title company found not only did she take the 3 year old old contract to her attorney and was untruthful that she was current and want to record an intrest on the title then a 9000. Judgment was place in her name for truck driving school on my home . The best part is i know the attorney very well and called him . He omitted that he just took their word and never checked the contract or license and notarized and recorded it and told the recording office to send verification to his office not to me .wow . Here i cant close im loosing the buyer cause he is scared. He call 2 days later apologized over and over that he found out she was untruthful and he would pay title insurance on it . I lost the customer and if i didnt close on that day i would have to pay much more in fees that i promised so i had to pay that as well . I know i can sue but is it worth it as far as money ? He did everything wrong and i paid dearly for his mistakes .

National Notary Association

14 May 2021

Hello. We're sorry, but we cannot provide legal advice regarding potential lawsuits. You would need to contact a qualified attorney for assistance.

Natalia Du

08 Apr 2021

The state of Missouri

National Notary Association

09 Apr 2021

Hello. For a traditional physical, permanently bound journal, a Missouri Notary is not required to request the signer's thumbprint for the journal entry. The Notary may ask the signer to voluntarily provide one, but the signer has the option to refuse. Electronic and Remote Online Notaries in Missouri must keep an electronic journal of their acts. The required entries for the Electronic Notary and Remote Online Notary electronic journal are the same as the permanently bound journal, but also require the electronic signature of each principal and credible witness, if applicable, and must include a recognized biometric identifier (RSMo 486.947.1[6][d] and 486.1185.1[6][d]).

Natalia Du

08 Apr 2021

If my state does not require a thumbprint can I have a client do one anyway?

National Notary Association

08 Apr 2021

Hello. To help us answer your question, can you please tell us what state you are commissioned in?

Michael Robinson

07 Apr 2021

Looking for more information about liability and/or E+O insurance. Can you assist?

National Notary Association

08 Apr 2021

Hello. Please see here for more information: https://www.nationalnotary.org/insurance/errors-omissions

Sueann valdes

06 Apr 2021

Love reading these articles, extremely informative.

Lani B.

05 Apr 2021

Hello, Can a notary notarize an acknowledgement's signature of a person who is deceased, if a creditable witness says she has POA and this person passed a few years before this notarization? I would think, even if the notary does not know this, the notary can still get into trouble...

National Notary Association

06 Apr 2021

Hello. To help us answer your question, can you please tell us what state you are commissioned in?

Ellen W Smith

21 Apr 2020

How long after you notarize a document can someone sue you. What if you are no longer a notary?

National Notary Association

22 Apr 2020

Hello. A Notary can be sued months or years after a notarization took place. Please see here for more information: https://www.nationalnotary.org/support/errors-and-omissions-insurance/minimize-your-liability

Roberta Danese Hammon

20 Apr 2020

What should I do if I receive a document notarized by another notary, but it is missing the "Notice" and the document contains blanks???

National Notary Association

20 Apr 2020

Based on what you’ve described, we think it would be best if you contacted our Hotline team by phone and provided them with a more detailed description of the situation. The NNA Hotline: 1-888-876-0827 Mon – Fri: 5:00 a.m. – 7:00 p.m. (PT) Saturday: 5:00 a.m. – 5:00 p.m. (PT) If you’re not an NNA Member or Hotline Subscriber, they will provide you with a one-time courtesy call.

James G Reynolds

02 Sep 2019

How do I get a E&O policy

National Notary Association

03 Sep 2019

Hello. Information on E&O policies through the NNA is available here: https://www.nationalnotary.org/support/faq/insurance#eo13

Craig Lambert

19 Jul 2019

How does one verify the insurance policy information for a notary. The notary is in Arizona.

National Notary Association

23 Jul 2019

Based on what you’ve described, we think it would be best if you contacted our Hotline team by phone and provided them with a more detailed description of the situation. The NNA Hotline: 1-888-876-0827 Mon – Fri: 5:00 a.m. – 7:00 p.m. (PT) Saturday: 5:00 a.m. – 5:00 p.m. (PT) If you’re not an NNA Member or Hotline Subscriber, they will provide you with a one-time courtesy call.

Brenda Burns

14 Jul 2018

My sister's husband had a new Will foged after her death and had a friend Notary to notorize tbe document that supposedly happened while she was alive. We had a hand writing expert testify tbat it was forged but because rhe notary's husband was a police officer snd the sposes son was a police officer the judge ignored it on bases that the notary and 2 witnesses that happened to be her daughter and son in law stood up in court and swore that they witnessed my sister sivn the new Will. In my book that is totally conspiracy and unfair. What can we do? Can we sue the notary personally? Thank you, Brenda Burns

National Notary Association

16 Jul 2018

Hi Brenda. Any questions regarding grounds for a lawsuit against a Notary would need to be answered by a qualified attorney.

Cynthia Helbert

07 Jul 2018

If a notary in Indiana notarized a fraudulently signed document, at a bank, who is liable, her or the bank she works for if she is deceased.xr7Uv5

National Notary Association

09 Jul 2018

Hello. Any questions regarding liability for a fradulent document would have to be decided in a court of law. If you have legal questions about a fraudulent document, you will need to contact a qualified attorney.

Lily Turner

26 Feb 2018

In the first two examples of lawsuits against a notary, the notary made no errors or omissions, so how is it that E&O insurance covered their legal expenses? I would have thought the expenses would have been covered by their bonding agency. Please clarify.

National Notary Association

01 Mar 2018

Hello. A surety bond does not provide coverage to the Notary. The surety bond is used to pay damages if a consumer suffers harm as the result of the Notary's negligence. For more information, please see here: https://www.nationalnotary.org/notary-bulletin/blog/2015/05/important-faqs-about-notary-eo-insurance

David L Phipps, Jr.

26 Feb 2018

Is a journal or thumb print required in Maryland?

National Notary Association

01 Mar 2018

Hello. Maryland Notaries must keep a journal of their acts, but are not required to take a thumbprint from signers for their journal entries. (ACM St. Gov. 18-107)

Jerilyn Atkinson

26 Feb 2018

I’m in Indiana had questions about journal

National Notary Association

26 Feb 2018

Hello. You can post your question here or contact our Hotline team at hotline@nationalnotary.org.

Jerilyn Atkinson

26 Feb 2018

I’m in Indiana I do a journal but it’s not required unless it changed

National Notary Association

26 Feb 2018

It's not required in Indiana, but is recommended by state officials.

Jerilyn Atkinson

22 Feb 2018

What states require the journal? If not required but I use one do u have to get thumb print?

National Notary Association

23 Feb 2018

Hello. If you are in a state where a Notary journal is not required by law, you may ask the signer for a thumbprint, but it is the signer's choice to provide one or not. The signer has the option to say no. If you can let us know what state you are in, we can provide you with information about your state's journal requirements.

Ray Leyva

09 Jan 2017

want to view

National Notary Association

09 Jan 2017

Hello. All our Bulletin articles are open to viewing by the public at no charge. If you are having trouble viewing an article, please contact us at social@nationalnotary.org with a description of the problem and we'll try to assist you.

R C Leyva

09 Jan 2017

need this information

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