Friday, August 30, 2019

FYI: 5th Cir Holds Refinance Mortgagee Not Entitled to Contractual Subrogation When DOT Invalid

The U.S. Court of Appeals for the Fifth Circuit held that a refinance lender is not entitled to contractual subrogation where it does not have a valid deed of trust.

 

Additionally, the Fifth Circuit certified the question of law to the Supreme Court of Texas regarding whether a lender is entitled to equitable subrogation where it failed to correct a curable constitutional defect in the loan documents under § 50 of the Texas Constitution.

 

A copy of the opinion is available at:  Link to Opinion

 

In 2007, a borrower ("Borrower") took out a purchase-money loan (the "2007 Loan") from a lender to buy her homestead, which was used as collateral for her loan.

 

In 2011, the Borrower took out a second loan (the "2011 Loan") from a different lender ("Lender") to refinance the debt.  The Lender and the Borrower executed an agreement for an extension of credit under § 50 of the Texas Constitution, secured by a lien on her homestead.

 

As you may recall, Section 50 of the Texas Constitution provides that no lien on a homestead shall be valid unless it complies with the requirements described in that section.  Among other things, it requires the owner of the homestead and the lender to sign a written acknowledgement of the fair market value of the homestead property on the date the extension of credit is made.

 

The Borrower's agreement with the Lender required the Lender to pay the balance of the 2007 Loan and release the remainder of the funds to the Borrower.  The agreement also contained an express subrogation provision, which provided that the Lender would be subrogated to all rights of any other holder of liens or debts outstanding before the agreement was executed. 

 

Upon the Lender's payment of the balance of the 2007 Loan, the prior lender released its claim on the homestead.

 

The Borrower subsequently notified the Lender that the loan documents for the 2011 Loan contained a constitutional deficiency – namely, that the Lender's signature did not appear on the acknowledgement of fair market value. 

 

In response, the Lender did not sign the document, but instead sent a new copy of the acknowledgement to the Borrower, with no explanation for the lack of signature.

 

Thereafter, a new entity ("Loan Owner") became the Lender's successor-in-interest for the 2011 Loan.

 

The Borrower sued the Loan Owner to quiet title, claiming that the Loan Owner's failure to comply with the Texas Constitution meant that the Loan Owner did not possess a valid lien on her property.  In its defense, the Loan Owner asserted that it was both contractually and equitably subrogated to the original 2007 lien, because its predecessor-in-interest paid off the remainder of that loan.

 

Both parties filed cross motions for summary judgment, and the district court granted summary judgment on the Borrower's quiet title claim and denied the Loan Owner's claim for contractual and equitable subrogation.  In reaching its decision, the trial court found that the Loan Owner could not avail itself of contractual subrogation because it did not have a valid contract.  The trial court also denied equitable subrogation because it found that the Loan Owner was negligent and therefore could not claim an equitable remedy.

 

The Loan Owner appealed the denial of its claim for both contractual and equitable subrogation.  Neither party disputed the validity of the 2007 Loan or the invalidity of the 2011 Loan.

 

On appeal, the Fifth Circuit first addressed the contractual subrogation claim, which it explained "arises from a valid deed of trust executed by both the borrower and lender."

 

The Court noted that the Loan Owner failed to sign the acknowledgement of fair market value as required, and that it did not cure the deficiency after being properly notified by the Borrower.  As a result, "it follows that the deed of trust is invalid, and that precludes any contractual subrogation."

 

The Fifth Circuit therefore affirmed the trial court's ruling on the contractual subrogation claim.

 

The Court next turned to the equitable subrogation claim, explaining that "equitable subrogation occurs when a subsequent lender pays off an existing debt, regardless of whether the subsequent loan was valid."

 

The Fifth Circuit stated that "[s]ince at least 1890, the Texas Supreme Court has applied equitable subrogation in the face of a constitutionally-invalid home-equity loan."  However, none of the cases "involve a constitutional defect that is exclusively the fault of the lender, as is the case here."

 

The Court then asked "[i]f the party seeking equitable subrogation could have satisfied the requirements of § 50(a)(6)(Q)(ix) but failed to do so, does that failure preclude it from invoking equitable subrogation?" 

 

Because the Supreme Court of Texas has never before answered that question, the Fifth Circuit certified the following question for the Supreme Court of Texas: "Is a lender entitled to equitable subrogation, where it failed to correct a curable constitutional defect in the loan documents under § 50 of the Texas Constitution?"

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

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Wednesday, August 28, 2019

FYI: 9th Cir Holds Supporting Evidence Not Required for CAFA Removal

The U.S. Court of Appeals for the Ninth Circuit recently reversed a trial court order remanding a case to state court for lack of jurisdiction under the federal Class Action Fairness Act ("CAFA") because the jurisdictional allegations pled provided a short and plain statement of jurisdiction.

 

The Court held this was sufficient, even without supporting evidence, to confer jurisdiction.

 

A copy of the opinion is available at:  Link to Opinion

 

A plaintiff filed a class action complaint against a defendant in California state court claiming that defendant "had engaged in unlawful business practices related to the advertisement and sale of residential internet services"  Plaintiff filed the case on behalf of himself and all California consumers that paid for defendant's internet services within the last four years.

 

Defendant removed the putative class action to the federal trial court pursuant to CAFA.  In the notice of removal, defendant, a citizen of Delaware and Georgia, alleged that it met CAFA's jurisdictional requirements "because it was a putative class action with more than 100 class members," and "that the amount in controversy exceeded $5,000,000, exclusive of interest and costs." Defendant also alleged that that minimal diversity existed between the parties because plaintiff and all class members were California Citizens.

 

Plaintiff moved to remand the case to state court by making a facial challenge to the notice of removal. Specifically, plaintiff argued that defendant had not "adequately plead the existence of minimal diversity" because defendant based the citizenship allegations solely "on information and belief."

 

The trial court granted plaintiff's motion to remand finding that defendant's citizenship allegations were insufficient to establish minimal diversity because they were based on no more than "sensible guesswork." This appeal followed.

 

The Ninth Circuit began its analysis by noting that Congress enacted CAFA with the "intent . . . to strongly favor the exercise of federal diversity jurisdiction over class actions with interstate ramifications."  CAFA gives federal trial courts jurisdiction over class actions when, "any member of a class of plaintiffs is a citizen of a State different from any defendant." 28 U.S.C. § 1332(d)(2)(A). In contrast to section 1332(a)'s complete diversity of citizenship requirement, the Ninth Circuit observed that CAFA only requires "minimal diversity."

 

The issue in this appeal is what the "removing defendant must plead in its notice of removal." 

 

The removing defendant has the burden to plead minimal diversity by including in the notice of removal "a short and plain statement of the grounds for removal." 28 U.S.C. § 1446(a).  Congress borrowed the "short and plain statement" standard from Rule 8(a), signifying to the Ninth Circuit that courts should liberally construe removal allegations similar to other pleadings.  The Ninth Circuit also noted that the removing defendant may plead minimal diversity based on "information and belief," without submitting evidence to support the allegations.

 

Defendant alleged that "all putative class members were citizens of California."  The Ninth Circuit rejected plaintiff's argument that defendant had to come forth with evidence to demonstrate why it believed its citizenship allegations. 

 

Instead, the Court held that a removing defendant may base its citizenship allegations "solely on information and belief."  Here, defendant's notice of removal contained the required short and plain statement that the putative class members were all California citizens necessary to confer jurisdiction under CAFA.

 

The Ninth Circuit also determined that the trial court erred by placing the burden on the removing defendant "to prove its jurisdictional allegations in response to" plaintiff's facial challenge.  Instead, jurisdictional factual allegations at the pleading stage "need not be proven unless challenged." This is especially true, the Ninth Circuit noted, because CAFA contains "no antiremoval presumption." 

 

The Ninth Circuit found it significant that plaintiff's motion to remand only facially challenged the legal adequacy of the notice of removal, instead of factually challenging the jurisdictional allegations because a facial challenge accepts the removing defendant's allegations as true and then argues that the allegations on their face fail to confer jurisdiction.  As a result, the Appellate Court held it was improper for the trial court to require defendant "to present evidence in support of its allegation of minimal diversity."

 

Thus, the Ninth Circuit held that defendant's jurisdictional allegations, which provided a short and plain statement of the parties' citizenships based on information and belief, met its burden to plead minimal diversity. 

 

The Ninth Circuit therefore reversed the trial court's order remanding the case to state court.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia   |   Illinois   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

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Monday, August 26, 2019

FYI: Cal App (3rd Dist) Allows HOBR Claim for Vague Reasons for Loan Mod Denial

The Court of Appeal for the Third District of California recently affirmed in part, and reversed in part, an order granting a mortgage servicer's motion to dismiss several causes of action brought by plaintiff borrowers for denying their requests to modify their mortgage loan.

 

The appellate court affirmed the dismissal as to the borrowers' counts for breach of contract, negligence, and intentional infliction of emotional distress.  However, it also held that the borrowers stated that a valid cause of action under California's Homeowner Bill of Rights, section 2923.6, and reversed as to that claim.

 

Specifically, the appellate court concluded that the servicer's explanation that it "do[es] not have the contractual authority to modify [the] loan because of limitations in [its] servicing agreement" was not sufficiently detailed, and that without knowing the actual reason for denial, it could not be said for certain that the failure to provide "specific reasons for the investor disallowance" as required under section 2923.6(f) was not material.

 

A copy of the opinion is available at:  Link to Opinion

 

After falling behind on their mortgage loan, the plaintiffs-borrowers ("Borrowers") requested loss mitigation assistance from their mortgage servicer ("Servicer") and alleged that they were offered a loan modification in exchange for agreeing to make three trial payments of $1,633.53.  Borrowers completed the trial payments but were not offered a modification, which led to Servicer recording a notice of default three months later.  After first dismissing an action against Servicer without prejudice, the Borrowers initiated the instant litigation in early 2014.

 

In late 2014, Borrowers submitted a completed loan modification application with supporting documents to Servicer to review Borrowers for a Home Affordable Modification Program ("HAMP") or a non-Hamp "Trial Payment Plan" modification.  Two months later, the Servicer denied the Borrowers for the HAMP modification, purportedly due to lack of contractual authority to modify the loan due to limitations in its servicing agreement.  However, the Borrowers were provided a non-Hamp Trial Payment Plan offer that required them to make three trial payments—the first one in the amount of $171,745.78—which was "essentially an initial payment of the past due total arrearages."

 

The Borrowers appealed the Servicer's denials, arguing that the non-Hamp Trial Payment Plan was a constructive denial and that they would have been approved if "fairly and carefully reviewed."

 

The Borrowers' operative third amended complaint alleged five causes of action against the Servicer for: (1) breach of contract, (2) violation of California's Business & Professions Code section 17200 (not at issue on appeal), (3) negligence, (4) violation of California's Homeowner Bill of Rights, section 2923.6, and (5) intentional infliction of emotional distress.

 

As was the case with the prior Complaints, the trial court sustained the Servicer's demurrer to the third amended complaint as to all causes of action, and this time, without leave to amend.  The instant appeal from the judgment of dismissal followed.

 

Initially, the Third District reviewed Borrowers breach of contract claim, which alleged that the Servicer had breached the written contract to extend a mortgage modification in exchange for three trial payments. 

 

The appellate court noted that the purported contract attached to the third amended complaint referred multiple times to the agreement Servicer offered as a "Special Forbearance Agreement," and expressly stated that it was "not a waiver of the accrued or future payments that become due, but a period for you to determine how you will be able to resolve your financial hardship."  Further, the purported "agreement" made no promise of a loan modification, but that "[t]he lender is under no obligation to enter into any further agreement," and completion of trial payments would result only in a review for a loan modification based on investor approval.

 

The Borrowers' argument that the temporary payment plan which led them to believe a permanent modification was forthcoming was tantamount to a binding contract was rejected by the trial court.  On appeal, they argued that the trial court erred in finding that the forbearance agreement did not obligate the Servicer to modify their mortgage loan, citing the 4th District's holding in West v. West v. JPMorgan Chase Bank, N.A. (2013) 214 Cal.App.4th 780, which held a "Trial Plan Agreement" required the lender to offer a permanent loan modification. 

 

The Third District similarly found Borrowers' argument unconvincing, and distinguished the facts from West, which offered a modification under HAMP, for the case at bar, which expressly disclaimed a promise to modify.  Whereas West was grounded in a Treasury directive and HAMP guidelines, the forbearance agreement here offered offer no comparable authority for imposing a similar obligation upon the Servicer.  Accordingly, the appellate court concluded that the Servicer's demurrer was properly sustained as to their breach of contract claim.

 

Borrowers' negligence claim argued that the Servicer owed them a general duty of care in the handling and processing of their loss mitigation review and negligently made false representations in promising a modification in exchange for trial payments. 

 

While acknowledging that a financial institution can owe a duty of reasonable care in processing loan modifications (Alvarez v. BAC Home Loans Servicing, LP (2014) 228 Cal.App.4th 941), the trial court sustained the Servicer's demurrer as to this count on the basis that Borrowers merely alleged that a nonexistent contract was not honored, and the claim for negligence per se similarly failed for failure to reference any such violation.

 

On appeal, the Borrowers argued that the failed to adequately apply Alvarez, and that a per se duty of care is also owed under California's Homeowner Bill of Rights.  The appellate court disagreed. 

 

Even assuming that the Servicer owed a duty of care in processing the loan application, the Third District held that Borrowers' third amended complaint failed to allege a breach or any facts that might suggest a failure to comply with any duty under Alvarez.  Thus, the trial court's decision to sustain the Servicer's demurrer as to Borrower's negligence claim was affirmed.

 

Next, the appellate court reviewed the dismissal of the Borrower's cause of action under California's Homeowner Bill of Rights.  In sustaining the Servicer's demurrer, the trial court rejected the Borrowers claims that their written denials were insufficiently detailed to comply with section 2923.6(f) on the basis that Borrowers' allegations were vague and they failed to provide authority that anything more was required.

 

As you may recall, Section 2923.6 subdivision (f) of the Homeowner Bill of Rights requires a servicer, following the denial of a loan modification, to send written notice "identifying the reasons for the denial."  Subdivision (f)(2) further requires that "[i]f the denial was based on investor disallowance, the specific reasons for the investor disallowance" must be given.  (§ 2923.6, subd. (f)(2)).

 

On appeal, the Third District analyzed the Servicer's denial for a HAMP modification, which explained that "[we] do not have the contractual authority to modify your loan because of limitations in our servicing agreement."  The appellate court concluded that the statement was ambiguous and did not suffice as an explanation – at least for the purposes of a demurrer. 

Although the Servicer argued that the purported violation was not material, as is required for a borrower to bring a claim for injunctive relief under section 2923.6 when a deed upon sale has not yet been recorded, the appellate court disagreed, reasoning that it could not determine whether the failure to provide "reasons for the disallowance" was not material without knowing the investor's actual reason for denying the HAMP modification.

 

Because the appellate court concluded that Borrowers stated a claim under section 2923.6, the trial court's order sustaining the demurrer to the Homeowner Bill of Rights claim was reversed.

 

Lastly, the Third District reviewed the sustained demurrer as to the Borrowers' intentional infliction of emotional distress claim—that the Servicer's refusal to provide a modification and offer approving modification conditioned only upon payment of $171,745.78 in arrearages constituted "extreme and outrageous" conduct.

 

In sustaining the demurrer, the trial court explained that creditors, such as the Servicer, enjoy a qualified privilege to protect their economic interest by asserting their legal rights—in this instance, to collect the 6-plus years of arrearages due on the loan—even though doing so may cause emotional distress. 

 

On appeal, the Borrowers argued that the trial court failed to adequately consider cases finding actionable conduct based on improper creditor action.  Bundren v. Superior Court (1983) 145 Cal.App.3d 784, 790 (creditor who knows the debtor is susceptible to emotional distress due to a physical or mental condition may incur liability for causing emotional distress).  The Borrowers claim that the Servicer knew its conduct was likely to cause more emotional distress than a typical debt collection because it knew they were trying to modify their loan since 2010 and could become homeless.  

 

While acknowledging that the Bundren court held that creditors could lose their qualified privilege to protect their economic interest if outrageous and unreasonable means are used to seek payment, the appellate court found no such conduct occurred here which "exceed[ed] all bounds usually tolerated by decent society, of a nature which is especially calculated to cause, and does cause, mental distress of a very serious kind." ' " (Christensen v. Superior Court (1991) 54 Cal.3d 868, 904–905.).  Thus, the demurrer was sustained as to the Borrowers' claims for intentional infliction of emotional distress.

 

For all of the foregoing reasons, the Third District reversed the trial court's order sustaining the demurrer as to the Borrowers' claims under the Homeowners' Bill of Rights, but affirmed as to all other counts, and remanded to the trial court for proceedings consistent with the appellate court's opinion.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

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Sunday, August 25, 2019

FYI: 7th Cir Holds Borrower's Fraud Claims Against Bank Not Barred by Res Judicata

The U.S. Court of Appeals for the Seventh Circuit recently reversed a trial court order determining that res judicata barred a borrower's fraud claims against a bank.

 

In so ruling, the Court held that, because in the first action the borrower was a defendant and raised the fraud claim before the bank voluntarily dismissed the case when the borrower learned of the fraud claims and threatened to allege them against the bank.

 

A copy of the opinion is available at:   Link to Opinion

 

A borrower and his business partner formed a company with the help of a loan from a bank. The borrower and his partner personally guaranteed the loan.  The company defaulted on the loan and the bank sued the company, the borrower, and his partner in Illinois state court.

 

The borrower retained counsel to defend him and the company.  The borrower raised several affirmative defenses to the complaint including "that the bank extended the maturity date of the loan without authorization that the bank charged fees and an interest rate not agreed upon, and that the bank charged excessive fees." 

 

The borrower's business partner never appeared.  The trial court eventually entered a default judgment against the business partner.

 

The borrower obtained an expert report concluding "that his signature had been forged on loan extension paperwork in 2010." The borrower sent the report to the bank's counsel, stating that he would file a suit against the bank alleging fraud.  Soon after this, the bank moved to voluntarily dismiss its claims against the borrower and the company without prejudice and the trial court granted the motion.

 

A little over a year later, the borrower sued the bank for fraud and other related claims alleging that he did not learn of the fraud in the first action in time to raise the claims before the bank dismissed the case.

 

The bank moved to dismiss the second action on res judicata grounds. The trial court granted the motion finding that the borrower should have brought his fraud claims in the first action. 

 

The borrower appealed, but before the Illinois Appellate Court heard the appeal, the bank was placed into federal receivership and the receiver removed the action to the U.S. District Court for the Northern District of Illinois under 12 U.S.C. § 1819(b)(2)(B).  The trial court adopted the Illinois trial court's opinion and this appeal followed.

 

As you may recall, Illinois allows a plaintiff to voluntarily dismiss their claim before the trial begins without prejudice.  735 Ill. Comp. Stat. 5/2- 1009(a).  Such a dismissal without prejudice does not involve a "final decision on the merits and that the plaintiff is not barred from refiling the action."  When a plaintiff voluntarily dismisses their claims against a defendant, this action "does not dismiss a pending counterclaim or third party complaint." 735 Ill. Comp. Stat. 5/2-1009(d).

 

Here, the borrower styled his claims in the original action as affirmative defenses, which in Illinois a defendant must raise in their answer to the complaint. 735 Ill. Comp. Stat. 5/2-613(d).  This is in contrast to counterclaims which are permissive and may be brought in a separate action. 735 Ill. Comp. Stat. 5/2-608.

 

The Seventh Circuit observed that Illinois has three requirements to apply res judicata to bar a subsequent lawsuit: "(1) a final judgment on the merits … entered in the first lawsuit by a court of competent jurisdiction; (2) an identity of causes of action exists; (3) the parties or their privies are identical in both lawsuits."  Illinois courts apply res judicata broadly to what was decided in the original action, and "to matters which could have been decided in that suit."

 

The Seventh Circuit found the majority of Illinois cases the trial court relied upon to conclude that res judicata barred the borrower's claims inapposite because they "involve a situation in which a plaintiff in the first action attempts to bring the same or similar claims in a later action — not a situation in which a defendant to the first action brings affirmative defenses as independent claims in the second action."  Nor does this appeal involve a final judgment in the first action that addressed the affirmative defenses that the borrower raises in the second action.

 

The Seventh Circuit reasoned that it was appropriate to apply the principles of equity in Illinois law to this case to allow the borrower to prosecute the second action for several reasons.  The borrower properly raised his affirmative defenses to the bank's claims in the first action. 

 

The bank obtained a default judgment in the first action against a defendant different than the borrower.  The borrower then produced a handwriting expert report and based on this report threatened to sue the bank for fraud.  In response, before the borrower brought any fraud claim against the bank in the first action, the bank dismissed its claims against the borrower without prejudice. 

 

As a result, the bank never defended against the fraud claims in the first action and the default judgment against a different defendant should not bar the borrower from pursuing his fraud claims against the bank in the second action.

 

The Seventh Circuit also determined that applying the doctrine of res judicata here would not advance the purposes behind the doctrine.

 

Res judicata is designed "to prevent a second litigation from undermining the prior judgment." Here, if the borrower prevails on his fraud claims against the bank in the second action, it will not give the borrower standing to challenge the default claim in the first action against a separate defendant.  Indeed, the borrower's second action only "seeks redress for the bank's alleged fraud but does not challenge the default judgment entered" against the separate defendant in the first action.

 

There is also no concern here about claim splitting according to the Seventh Circuit because the borrower was a defendant in the first action and did not dismiss the first action.

 

Finally, the Seventh Circuit believed that applying the doctrine of res judicata here would not serve the interests of judicial economy.  The court in the first action "never considered or weighed in on" the borrower's fraud claims because the bank dismissed its claims against the borrower without prejudice.  The bank never litigated the fraud claim in the first action and defending against this claim in the second action "will not force the bank into redundant litigation."

 

Thus, the Seventh Circuit reversed the trial court order determining that res judicata barred the borrower's claims and remanded for further proceedings consistent with its opinion.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia   |   Illinois   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

Financial Services Law Updates

 

and

 

The Consumer Financial Services Blog

 

and

 

Webinars

 

and

 

California Finance Law Developments