The General Rule.- In 1900 a standard encyclopedia said: "By the weight of authority an abstracter is liable only to the person ordering and paying for the abstract; and where this view obtains, the fact that an abstracter has knowledge that his abstract is to be used in a sale or loan to advise a purchaser or person about to lend money does not affect the rule as to his liability. In some jurisdictions, however, the abstracter's liability has been extended to protect those who, relying on the correctness of the abstract, are injured."
Harry R. Trusler,
Extension of Liability of Abstracters,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol18/iss2/4