FYI: Cal App Ct (2nd Dist) Holds Interest Payment Not Required on Escrowed Hazard Insurance Proceeds

The Court of Appeals of the State of California, Second Appellate District (Second District), recently held that neither California Civil Code section 2954.8 nor the parties' loan agreement required the mortgagee to pay interest on insurance proceeds it held in escrow following the destruction of the plaintiff's home.

 

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

 

The plaintiff's home was destroyed by a wildfire and his hazard insurance policy jointly paid him and his mortgages, the defendant, a total of $1,342,740. The Deed of Trust allowed the mortgagee to hold the insurance proceeds in escrow and to disburse the funds as repairs to the home were being made. Accordingly, the mortgagee placed the funds in a non-interest bearing escrow account.

 

The plaintiff then brought suit, alleging that the mortgagee breached its fiduciary duty and violated Civil Code section 2954.8 and Business and Professions Code section 17200. The plaintiff argued that section 2954.8 requires a mortgagee to pay interest on insurance proceeds held in escrow following the partial or total destruction of the insured's residence or other structure.

 

The trial court sustained the mortgagee's demurrer to the complaint without leave to amend, and the plaintiff appealed.

 

Section 2954.8, subdivision (a), requires a lender "that receives money in advance for payment of taxes and assessments on the property, for insurance, or for other purposes relating to the property" to pay two percent interest per annum on the amount being held. Section 2954.8. The plaintiff argued that the hazard insurance proceeds the defendant received count as "money in advance."

 

The Deed of Trust in this matter required the plaintiff to maintain hazard insurance on his home, and further stated: "During such repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or earnings on such proceeds" (italics added).

 

The Second District noted that Lippitt v. Nationstar Mortgage, LLC (C.D. Cal. Apr. 16, 2020, No. SA CV 19-1115-DOC-DFM) 2020 U.S. Dist. Lexis 122881, addressed nearly identical facts to the matter at hand. The Lippitt court, reading the borrower's Deed of Trust in conjunction with section 2954.8's plain language, concluded that section 2954.8 does not apply to insurance funds received in arrears for past losses and then held for specified purposes. Id. at 20. The court in Lippitt did not consider these funds "money in advance." Id.

 

The Second District agreed with the Lippitt court and held that, based upon the contractual language and the plain language in the statute, section 2954.8 applies to common escrows maintained to pay taxes, assessments, and insurance premiums, not to the unique scenario of hazard insurance proceeds held by a lender pending property rebuilding. Id. at 21.

 

The Second District also concluded that the plaintiff's secondary reliance on the supposed purpose of section 2954.8 cannot override the plain language of the statute. "The statute's plain meaning controls the court's interpretation unless its words are ambiguous. If the plain language of a statute is unambiguous, no court need, or should, go beyond that pure expression of legislative intent." White v. Ultramar, Inc. (1999) 21 Cal.4th 563, 572.

 

Given that the Second District determined that no section 2954.8 violation occurred, it did not address whether the statute creates a private right of action or whether, by failing to pay interest on the insurance proceeds, the mortgagee breached its fiduciary duties and engaged in unfair competition.

 

Accordingly, the Second District concluded that the insurance proceeds held by the mortgagee pursuant to the Deed of Trust fall outside the scope of section 2954.8, and affirmed the trial court's ruling sustaining the mortgagee's demurrer to the complaint without leave to amend.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 6^th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
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Mobile:  (312) 493-0874
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Admitted to practice law in Illinois

 

 

 

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FYI: SCOTUS Dials Back the TCPA

The federal Telephone Consumer Protection Act can no longer apply to devices that do not "us[e] a random or sequential number generator," according to an April 1, 2021 decision from the U.S. Supreme Court.

 

For businesses that use telephone technology that does not use a random or sequential number dialer – and there are many that do not – the Court's 9-0 ruling in Facebook, Inc. v. Duguid should significantly reduce the risk of TCPA litigation for businesses using telephone technology to call their customers.

 

The case arose after Duguid received on his cell phone several text messages from Facebook warning him that someone had accessed his Facebook account. Duguid did not have a Facebook account. Facebook believed Duguid was assigned a cell phone number that had once belonged to a customer who requested to receive these notifications. Duguid sued Facebook alleging it violated the TCPA when it stored cellular phone numbers and then used its equipment to send automated messages to him without his consent.

 

Facebook argued that its text messaging system was not an "automatic telephone dialing system" (ATDS) subject to the TCPA. The trial court agreed and dismissed the case. The Ninth Circuit Court of Appeals reversed, holding that because Facebook's equipment had the capacity to "store numbers" to be texted and could "dial such numbers automatically" it was an ATDS subject to the TCPA. The Supreme Court reversed the decision of the Court of Appeals finding that the Facebook equipment was not an ATDS because it lacked the capacity "to store or produce telephone numbers . . . using a random or sequential number generator" and to call those numbers.

 

Although Duguid concerns text messages, it equally applies to calls to cellular phones.

 

The TCPA and Its Litigation Machine

 

To fall within the TCPA, the call must be made using an ATDS. The TCPA itself provides a definition that would seem to limit its application to equipment which has the capacity "to store or produce telephone numbers to be called, using a random or sequential number generator" and to call those numbers.

 

Enacted in 1991 with the stated purpose of curtailing robocall solicitations, courts and even the federal agency tasked with TCPA rulemaking – the Federal Communications Commission – gave such broad interpretations to what constitutes an ATDS that at times any type of device, save for a rotary telephone, could be construed as subject to the TCPA.

 

Calls made by businesses to their customers were often the target of TCPA lawsuits and because of the expansive interpretations, a business need not have used equipment that used a random or sequential number generator to find itself paying out TCPA awards and settlements. With statutory damages of up to $1,500 per violating call, TCPA litigation was lucrative, especially TCPA class actions.

 

A Present Capacity as a Random or Sequential Number Generator

 

Under the decision, to come within the ambit of the TCPA, an ATDS must have the capacity to store telephone numbers using a random or sequential number generator or produce telephone numbers using a random or sequential number generator.

 

Some will argue that the reference to "capacity" leaves open the argument that although the dialed number did not originate from a random or sequential number generator, the equipment still had the capacity to do so and would bring the call within the TCPA.

 

But as the decision noted, "Congress' definition of an autodialer requires that in all cases, whether storing or producing numbers to be called, the equipment in question must use a random or sequential number generator" and "[t]he statutory context confirms that the autodialer definition excludes equipment that does not 'us[e] a random or sequential number generator.'"

 

"Capacity," as the decision is using it, is better read to mean the equipment's present capacity, and not a potential capacity to do so. This leaves businesses and their telephone equipment vendors in a far better position to control TCPA risk.

 

"Human Intervention" Takes a Punch

 

The absence of "human intervention" is how one line of TCPA case law interpreted an ATDS. Simply put, if a human did not punch a button to initiate the call, the device was construed to be an ATDS subject to the TCPA and Duguid asked the Court to adopt this interpretation.

 

The Court refused to stretch the TCPA "as malleably" as he would like. In a footnote, the Court also rejected the approach, reasoning that "all devices require some human intervention . . ."

 

Storing and Dialing Alone Is Not Sufficient To Demonstrate an ATDS

 

The decision certainly puts an end to the interpretation that the TCPA is triggered by merely storing and dialing numbers automatically. "Expanding the definition of an autodialer to encompass any equipment that merely stores and dials telephone numbers would take a chainsaw to these nuanced problems when Congress meant to use a scalpel," Justice Sotomayor wrote in delivering the Court's opinion.

 

The Future of TCPA Litigation

 

In reversing Duguid, the decision also overrules an earlier decision from the Ninth Circuit Court of Appeals which afforded a broad interpretation to what constitutes an ATDS; namely, equipment that stores and dials telephone numbers.

 

A significant number of cases are still pending in trial and appellate courts that have been awaiting the Duguid decision and we will soon see how it will be applied by a varied number of courts. Expect a good deal of argument concerning the meaning of "capacity."

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 6^th 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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FYI: 6th Cir Holds Federal Eviction Moratorium Exceeds Congressional Authority

The U.S. Court of Appeals for the Sixth Circuit recently denied an emergency motion to stay a trial court's order ending the federal Centers for Disease Control and Prevention's (CDC) moratorium on residential evictions.

 

In so ruling, the Sixth Circuit held that the plain meaning and ejusdem generis canons of interpretation indicate that 42 U.S.C. § 264 does not allow the CDC to halt evictions.

 

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

 

The March 2020 "CARES Act" included a 120-day moratorium on eviction filings based on nonpayment of rent for tenants residing in certain federally financed rental properties, which expired in July 2020. Pub. L. No. 116-136, § 4024(b), 134 Stat. 281 (2020).

 

The CDC Director then unilaterally issued the "Halt Order" declaring a new moratorium, halting evictions of certain "covered persons" through December 31, 2020, purportedly based on authority found in Section 361 of the Public Health Service Act, 42 U.S.C. § 264, which provides the Secretary of Health and Human Services with the power to "make and enforce such regulations as in his judgment are necessary to prevent the introduction, transmission, or spread of communicable diseases." 85 Fed. Reg. 55292-01.

 

Congress subsequently passed the Consolidated Appropriations Act, which extended that Halt Order from December 31 to January 31. Pub. L. No. 116-260, § 502, 134 Stat. 1182 (2020).

 

Just before that statutory extension lapsed, the CDC Director issued a new directive extending the order through March 31, 2021, again relying on the generic rulemaking power arising from the Public Health Service Act. 86 Fed. Reg. 8020-01 (citing 42 U.S.C. § 264(a)).

 

The plaintiffs in this case all own or manage residential rental properties. In September 2020, the plaintiffs challenged the Halt Order and sought a declaratory judgment that the Halt Order violated the Administrative Procedures Act and a preliminary injunction barring its enforcement. The trial court denied the preliminary injunction because it found that the plaintiffs' loss of income did not rise to the level of an irreparable injury.

 

The government then moved for judgment on the pleadings. The plaintiffs countered with a Rule 56 motion for judgment on the administrative record. The trial court granted judgment in the plaintiffs' favor, finding that the Halt Order exceeded the CDC's statutory authority under 42 U.S.C. § 264(a).

 

The government appealed and moved the trial court for an emergency stay of its order granting judgment in favor of the plaintiffs because the Halt Order is set to expire on March 31. However, when the trial court did not oppose the plaintiffs proposed two-week response date (well past March 31), the government filed a stay motion before the Sixth Circuit.

 

The Sixth Circuit considers four factors when deciding whether to stay a judgment pending appeal: "(1) whether the stay applicant has made a strong showing that he is likely to succeed on the merits; (2) whether the applicant will be irreparably injured absent a stay; (3) whether issuance of the stay will substantially injure the other parties interested in the proceeding; and (4) where the public interest lies." Nken v. Holder, 556 U.S. 418, 434 (2009) (quotation and brackets omitted). When a party has no likelihood of success on the merits, the Court does not grant a stay. SawariMedia, LLC v. Whitmer, 963 F.3d 595, 596 (6th Cir. 2020) (quoting Daunt v. Benson, 956 F.3d 396, 421–22 (6th Cir. 2020)).

 

Congress' express authorization of the Halt Order ended on January 31, when the order was set to expire under the Consolidated Appropriations Act. At that point, the CDC Director had to rely solely on the rulemaking power stipulated in 42 U.S.C. § 264 to extend the Halt Order.

 

Under Section 264(a), the HHS Secretary, and the CDC by extension, "may provide for such inspection, fumigation, disinfection, sanitation, pest extermination, destruction of animals or articles found to be so infected or contaminated as to be sources of dangerous infection to human beings, and other measures, as in his judgment may be necessary." 42 U.S.C. § 264(a). The government asserted that a nationwide eviction moratorium is among the "other measures" for disease control that Congress envisioned when drafting the statute.

 

The Sixth Circuit disagreed and held that a catchall provision at the end of a list of specific items warrants application of the ejusdem generis canon, which says that "where general words follow specific words in a statutory enumeration, the general words are construed to embrace only objects similar in nature to those objects enumerated by the preceding specific words." Circuit City Stores, Inc. v. Adams, 532 U.S. 105, 114–15 (2001) (citation omitted).

 

The Court reasoned that a right to intrude on property to sanitize and dispose of infected materials is altogether different from a right to halt evictions.

 

Additionally, the Sixth Circuit noted, regulation of the landlord-tenant relationship is historically left up to the states to handle. Loretto v. Teleprompter Manhattan CATV Corp., 458 U.S. 419, 440 (1982) ("[t]his Court has consistently affirmed that States have broad power to regulate housing conditions in general and the landlord-tenant relationship in particular"). Therefore, the Sixth Circuit stated that even if it were inclined to read section 264(a) as allowing the CDC to halt evictions, it cannot do so without some clear, unequivocal textual evidence of Congress' intent to do so. Will v. Mich. Dep't of State Police, 491 U.S. 58, 65 (1989).

 

The government argued that (i) a later subsection of section 264 acknowledges the HHS Secretary's authority to enforce quarantines, (ii) quarantines are not among the enumerated provisions of section 264(a), (iii) quarantines are different in kind from the enumerated provisions, and therefore, (iv) "other measures" must be read more expansively than the ejusdem

generis canon allows. The Sixth Circuit was not persuaded because it concluded that the later subsection was specifically concerned with the CDC's power to restrict liberty interests to avoid the spread of disease, and section 264(a) is only focused on property interest restrictions.

 

The government then contended that when Congress legislatively extended the Halt Order to January 31 through the Consolidated Appropriations Act, it effectively acknowledged that section 264(a) authorizes the Halt Order. Again, the Sixth Circuit disagreed.

 

The Court noted that Congress referenced the CDC's assertion that the Halt Order is supported by section 264(a) when it passed the Consolidated Appropriations Act. However, the Sixth Circuit held that congressional acquiescence does not take precedence over the plain text of section 264(a), which does not authorize the CDC to ban evictions.

 

The Sixth Circuit held that Congress does have "the power to ratify . . . acts which it might have authorized and give the force of law to official action unauthorized when taken." Swayne & Hoyt, Ltd. v. United States, 300 U.S. 297, 301-02 (1937) (internal citation omitted). However, nothing in the Consolidated Appropriations Act expressly approves the CDC's interpretation of section 264(a). H.R. 133, 116th Cong., div. N, tit. V, § 502.

 

Because the Sixth Circuit decided that the government is unlikely to succeed on the merits, the Court did not consider the remaining stay factors. See Maryville Baptist Church, Inc. v. Beshear, 957 F.3d 610, 615–16 (6th Cir. 2020).

 

As a result, the Sixth Circuit denied the government's emergency motion to stay the trial court's order pending appeal.

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 6^th 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   |   Tennessee   |   Texas   |   Washington, DC

 

 

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FYI: 5th Cir Rejects Chpt 13 Debtor's Attempt to "Partially Surrender" Different Collateral for Same Claim

The U.S. Court of Appeals for the Fifth Circuit recently affirmed a trial court's denial of a consumer's Chapter 13 bankruptcy plan that proposed a "partial surrender" of a cross-collateralized loan.

 

In so ruling, the Fifth Circuit held that the text of 11 U.S.C. § 1325(a)(5) allows debtors to select a different option "with respect to each allowed secured claim," but it does not allow a debtor to select different options for different collateral securing the same claim.

 

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

 

In June 2017, the consumer filed for Chapter 13 bankruptcy at a time when he had outstanding balances on two car loans with the defendant. The loans were cross-collateralized, meaning that Car A and Car B were both pledged as collateral for each loan. The defendant had filed two separate Proofs of Claim, one for the Car A loan (the "Car A Claim"), and one for the Car B loan (the "Car B Claim").

 

The consumer decided that he could only afford to keep one car, so his bankruptcy plan (the "Plan"), citing 11 U.S.C. § 1325(a)(5), proposed that he retain Car A, "cram down" the Car A Claim, and surrender Car B to the defendant as collateral for the Car B Claim.

 

The defendant filed an objection to the Plan, specifically the "partial surrender" of collateral under the Car B Claim, arguing that the cross-collateralization provisions in the loans prevented the consumer from surrendering Car B and retaining Car A.

 

The bankruptcy court entered an order confirming the Plan. The defendant filed a motion for a new trial, which the bankruptcy court denied. The defendant appealed the orders confirming the Plan and denying the motion for a new trial to the trial court. The trial court reversed the bankruptcy court's order confirming the Plan and remanded the case for further proceedings in accordance with its order. The consumer appealed.

 

Section 1325(a) of the Bankruptcy Code contains a number of requirements regarding a bankruptcy court's confirmation of a Chapter 13 plan. Subsection (a)(5) governs a plan's treatment of an allowed secured claim:

 

(a) Except as provided in subsection (b), the court shall confirm a plan if—

....

(5) with respect to each allowed secured claim provided for by the plan—

(A) the holder of such claim has accepted the plan;

(B)(i) the plan provides that—

(I) the holder of such claim retain the lien securing such claim until the earlier of—

(aa) the payment of the underlying debt determined under nonbankruptcy law; or

(bb) discharge under section 1328; and

(II) if the case under this chapter is dismissed or converted without completion of the plan, such lien shall also be retained by such holder to the extent recognized by applicable nonbankruptcy law;

(ii) the value, as of the effective date of the plan, of property to be distributed under the plan on account of such claim is not less than the allowed amount of such claim; and

(iii) if—

(I) property to be distributed pursuant to this subsection is in the form of periodic payments, such payments shall be in equal monthly amounts; and

(II) the holder of the claim is secured by personal property, the amount of such payments shall not be less than an amount sufficient to provide to the holder of such claim adequate protection during the period of the plan; or

(C) the debtor surrenders the property securing such claim to such holder . . .

 

Section 1325(a)(5)(B) provides the so-called "cram down" option, which allows the debtor to keep the collateral over the objection of the creditor and provide the creditor with payments that, over the life of the plan, will total the present value of the collateral. Assocs. Com. Corp. v. Rash, 520 U.S. 953, 957 (1997).

 

The consumer argued that the plain language of section 1325(a)(5) requires a debtor to select an option "with respect to each allowed secured claim," and allows debtors to select different options for each individual claim against their estate.

 

The defendant, on the other hand, argued that because section 1325(a)(5) presents its options using the conjunction "or," the consumer must select one of the three options for each secured claim —he may not select different options for different collateral securing the same claim.

 

The bankruptcy court agreed with the consumer, but the trial court agreed with the defendant and held that the consumer must either cramdown or surrender all of the collateral securing the Car B Claim, meaning both Car A and Car B.

 

The Fifth Circuit agreed with the defendant and the trial court, stating that section 1325(a)(5)'s use of the conjunction "or" between the options provided in subsections (A), (B), and (C) makes it clear that debtors may choose only one of those three options for each claim. The Court held that, even though section 1325(a)(5) does allow a bankruptcy plan to select a different option for each claim, the plan violates section 1325(a)(5) when it selects different options for different collateral securing the same claim. 

 

The Fifth Circuit's ruling in Williams v. Tower Loan of Mississippi (In re Williams), 168 F.3d 845 (5th Cir. 1999) supported the Court's decision here. In Williams, a debtor's plan sought to address one secured claim by surrendering some of the collateral securing the claim and paying the cram down value of the remaining collateral. Id. at 846. The Fifth Circuit held that the debtor's plan could not be approved because "[t]he plain language of [section 1325(a)(5)] does not give the debtor the right to adopt a combination of the options offered in (B) and (C)." Id. at 847.

 

In Williams, the Fifth Circuit adopted the reasoning behind First Brandon Nat'l Bank v. Kerwin (In re Kerwin), 996 F.2d 552 (2d. Cir. 1993), where the Second Circuit held that a debtor had to choose the option provided in either subsection (B) or (C) and could not mix-and-match. Id. (citing Kerwin, 996 F.2d at 556-57).

 

The Fifth Circuit also cited the Supreme Court of the United States's ruling in Assocs. Com. Corp. v. Rash, 520 U.S. 953 (1997) in the Williams decision. Id. In Rash, the Supreme Court held that (1) "[a] plan's proposed treatment of secured claims can be confirmed if one of three conditions is satisfied" and (2) "[i]f a secured creditor does not accept a debtor's Chapter 13 plan, the debtor has two options for handling allowed secured claims: surrender the collateral to the creditor . . . or, under the cram down option, keep the collateral over the creditor's objection." Rash, 520 U.S. at 957. In the view of the Fifth Circuit, this ruling "strongly indicates that a debtor cannot combine subsections (B) and (C) to create a fourth option." Williams, 168 F. 3d at 847.

 

The consumer argued that because Williams only involved one claim, it did not address section 1352(a)(5)'s requirement that a debtor make a unique decision with respect to "each" secured claim. The bankruptcy court agreed with the consumer and held that Williams is factually distinct from this case. However, the trial court held that because only one claim is at issue in this matter, the Car B Claim, the ruling in Williams is clearly applicable.

 

The Fifth Circuit agreed with the trial court, holding that debtors must select the same section 1325(a)(5) option for all of the collateral securing a single claim, as was decided in Williams. Applying that rule to the Car B Claim, the Fifth Circuit concluded that for the Plan to be approvable under section 1325(a)(5), the Plan must select the same § 1325(a)(5) option for both items of collateral securing the Car B Claim— Car A and Car B.

 

Accordingly, the Fifth Circuit held that the Plan violated the plain language of section 1325(a)(5) and affirmed the ruling of the trial court.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 6^th 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   |   Tennessee   |   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.

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