FYI: 9th Cir Holds Mortgage-Savings Clause Not Enough to Undo HOA's Foreclosure Sale

The U.S. Court of Appeals for the Ninth Circuit recently affirmed a trial court's grant of summary judgment in favor of the defendant homeowner's association in an action brought by the plaintiff mortgagee seeking to set aside the foreclosure sale of real property in Nevada.

 

In so ruling, the Ninth Circuit predicted that the Nevada Supreme Court would adhere to its own unpublished decisions and hold that a mortgage-savings clause, by itself, does not constitute unfairness that affects a sale, and held that the clause was void because it conflicted with Nev. Rev. Stat. 116.3116(2) and Nev. Rev. Stat. 116.1104.

 

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

 

Prior to 2015, Nevada law permitted a homeowners association to place a lien on real property for any delinquent payments. See generally Bank of America, N.A. v. Arlington W. Twilight Homeowners Ass'n, 920 F.3d 620, 621–22 (9th Cir. 2019) (per curiam).

 

Any portion of the lien that consisted of the last nine months of unpaid monthly assessments, or any unpaid maintenance or nuisance-abatement charges, had "superpriority" status over all other liens, including the first deed of trust. Id. at 622. If the homeowners association conducted a foreclosure sale on the lien and complied with statutory procedural requirements, the sale extinguished the first deed of trust. Id.

 

In 2013, a limited liability company owning a home fell behind on payments to the first defendant, the original homeowner's association ("First HOA"). The defendant First HOA recorded a lien and then a notice of default and election to sell. The plaintiff, the mortgagee holding the first deed of trust, took no action at the time to preserve its deed of trust.

 

At the foreclosure sale, the second defendant, the new homeowner's association ("Second HOA"), bid the highest amount. The foreclosure sale complied with all statutory requirements, and a portion of the lien had superpriority status. Pursuant to Nevada law, the sale thus extinguished the first deed of trust.

 

The plaintiff mortgagee then brought an action in federal court, asking the trial court to set aside the sale as a matter of equity. The Second HOA filed counterclaims against the plaintiff and other entities, seeking to quiet title in its favor. The trial court granted summary judgment to the defendant HOAs, quieting title in the Second HOA's favor and declining to set aside the sale. The plaintiff timely appealed.

 

In this case, a mortgage-savings clause in the applicable covenants, conditions, and restrictions ("CC&Rs") provided, contrary to Nevada law, that any lien for unpaid assessments would be subordinate to the first deed of trust. The plaintiff argued that the clause, by itself, constituted unfairness that affected the sale.

 

The primary question in this case was thus one of state law: whether the mortgage-savings clause in the CC&Rs constituted unfairness that affected the sale such that the trial court had equitable discretion to set aside the foreclosure sale.

 

In a diversity case, the published decisions of the Nevada Supreme Court bind federal courts as to the substance of Nevada law. Albano v. Shea Homes Ltd. P'ship, 634 F.3d 524, 530 (9th Cir. 2011). Here, though, the Nevada Supreme Court had not addressed directly, in any published decision, the effect of a mortgage-savings clause by itself.

 

Therefore, the Ninth Circuit determined that its role was to predict how the Nevada Supreme Court would resolve the question in a published opinion. To do this, the Court looked to the Nevada Supreme Court's unpublished decisions, which held that a mortgage-savings clause, by itself, does not constitute unfairness that affects a sale.

 

Under Nevada law, courts retain discretion to set aside a foreclosure sale if two circumstances are present: (1) an unreasonably low sales price, and (2) fraud, unfairness, or oppression that affected the sale. Nationstar Mortg., LLC v. Saticoy Bay LLC Series 2227 Shadow Canyon, (Shadow Canyon) 405 P.3d 641, 648 (Nev. 2017). However, if the record contains "no evidence that the sale was affected by fraud, unfairness, or oppression, then the sale cannot be set aside regardless of the inadequacy of price." Shadow Canyon, 405 P.3d at 648– 49.

 

Here, the purchase price was approximately 8% of the market value of the property. Because of that low purchase price, the Ninth Circuit reasoned that the plaintiff must produce only slight evidence of fraud, unfairness, or oppression that affected the sale. Id. at 648.

 

The plaintiff mortgagee pointed to the mortgage-savings clause in the CC&Rs as evidence of unfairness that affected the sale. The clause stated, contrary to Nevada law, that any lien for unpaid assessments would be subordinate to any lien by the first deed of trust.

 

The Ninth Circuit declared that the mortgage-savings clause was void as a matter of Nevada law. See SFR Invs. Pool 1, LLC v. U.S. Bank, N.A., 334 P.3d 408, 419 (Nev. 2014) (en banc) (holding that a similar mortgage-savings clause was void). The clause conflicted with Nevada Revised Statutes section 116.3116(2), which required liens for unpaid assessments to have superpriority status. Id. Additionally, section 116.1104 provided that the priorities cannot be modified by agreement. Id.

 

The Ninth Circuit also observed that the mortgage-savings clause was void under the terms of the CC&Rs themselves. A provision of the CC&Rs expressly stated that if any provision conflicted with chapter 116 of the Nevada Revised Statutes, then "such offending Declaration provision shall be automatically deemed modified or severed herefrom."

 

However, the Ninth Circuit held that the plaintiff mortgagee had not introduced any evidence that the clause misled the plaintiff or that the mortgage-savings clause affected the sale at all.

 

According to the Ninth Circuit, the Nevada Supreme Court has repeatedly rejected in unpublished opinions the same argument that the plaintiff advanced here.

 

For instance, in U.S. Bank Nat'l Ass'n as Trustee for Benefit of HarborView 2005–08 v. Vistas Homeowners Ass'n, 432 P.3d 191, 2018 WL 6617731 (Nev. 2018) (unpublished), the Nevada Supreme Court held that a mortgage-savings clause did not constitute unfairness because the appellants in that case did not present "any evidence that potential bidders were misled by the CC&Rs' protective covenant and that bidding was chilled. Moreover, [the Nevada Supreme Court] must presume that any such bidders also were aware of NRS 116.1104, such that they were not misled." Id. at *1.

 

The Ninth Circuit distinguished this case from ZYZZX2 v. Dizon, No. 2:13-cv-1307, 2016 WL 1181666 (D. Nev. Mar. 25, 2016), which concerned a mortgage-savings clause and a letter affirmatively stating that the specific sale at issue would not extinguish the first deed of trust. Id. at *5. The mortgagee in Dizon therefore had no reason to protect its interest because, according to the letter, the mortgagee's interest was not threatened.

 

The Ninth Circuit concluded that the type of individualized affirmative misrepresentation at issue in Dizon is clearly unfair. By contrast, the Court held that the mortgage-savings clause in the present case was void as a matter of law and did not, by itself, constitute unfairness that affected the sale.

 

The Ninth Circuit noted that the Nevada Supreme Court has repeatedly distinguished Dizon for the same reasons in unpublished opinions. For example, in HarborView, 2018 WL 6617731, after holding that no prospective buyer could have been misled by the mortgage-savings clause, the court held in a footnote that "to the extent it is persuasive, ZYZZX2 v. Dizon, 2016 WL 1181666 (D. Nev. 2016), is distinguishable because in addition to the CC&Rs' covenant, the HOA [in Dizon] sent a letter to the deed of trust beneficiary affirmatively misrepresenting to the beneficiary that it would not need to take any action to protect its deed of trust." HarborView, 2018 WL 6617731, at *1 n.2.

 

Therefore, the Ninth Circuit held that, under Nevada law, the mortgage-savings clause did not constitute fraud, unfairness, or oppression that affected the sale.

 

The dissenting opinion in this case stated that the Ninth Circuit should have certified the question to the Nevada Supreme Court. However, the majority concluded that its role in a diversity case is to "predict how the state high court would resolve" a question in a published decision, Albano, 634 F.3d at 530, and that the Court regularly decides issues of state law without certifying questions to the state's highest court.

 

The Ninth Circuit also rejected the plaintiff mortgagee's remaining arguments and concluded that no unfairness arose from the first defendant's processing of payments and that the notice at issue, which complied with statutory requirements, did not violate due process.

 

Accordingly, the Ninth Circuit held that, because the mortgage-savings clause did not affect the foreclosure sale, the sale could not be set aside, and title vested with the Second HOA, the purchaser at the sale. Thus, the Court affirmed the trial court's grant of summary judgment in favor of the Second HOA.

 

 

 

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: 5th Cir Holds FDCPA Plaintiff Not Entitled to Attorney's Fees Following Settlement

The U.S. Court of Appeals for the Fifth Circuit recently affirmed a trial court's denial of an award to attorney fees to a debtor who settled her claims against a debt collector for purported violations of the federal Fair Debt Collection Practices Act, 15 U.S.C. 1692, et seq. ("FDCPA") and parallel state law consumer protection statutes.

 

In so ruling, the Fifth Circuit concluded that the fee-shifting provision under the FDCPA for a "successful action to enforce the foregoing liability" requires that a lawsuit generates a favorable end result compelling accountability and legal compliance with a formal command or decree under the FDCPA, and that reaching settlement before any such end result does not entitle a plaintiff to an award of attorneys' fees under the statute.

 

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

 

A consumer ("Debtor") sued a debt collector ("Debt Collector") for purported violations of the FDCPA and parallel provisions of Texas state law.  After the parties' cross-motions for summary judgment were denied on the basis that triable issues of fact existed, the parties reached a settlement before trial wherein the Debt Collector agreed to waive the outstanding debt (approximately $2100) and pay $1,000 damages. 

 

After apprising the trial court of the settlement, the court entered sanctions against the Debtor's attorneys, ordering thousands of dollars in costs and fees and reporting them to the disciplinary committee of the U.S. District Court for the Western District of Texas for purportedly bringing the case in bad faith.  See Tejero v. Portfolio Recovery Assocs., L.L.C., 955 F.3d 453, 457. 

 

The Debtor appealed, and the Fifth Circuit reversed the imposition of sanctions for abuse of discretion and remanded for the trial court to determine in the first instance whether the Debtor's favorable settlement entitled him to attorneys' fees under the FDCPA.  Id. at 462-463.  The district court said no, which led to the instant appeal.

 

In this appeal, the sole question before the Fifth Circuit was whether the trial court erred in refusing the Debtor's fee application under the FDCPA.

 

The United States generally employ the "American Rule" wherein "[e]ach litigant pays his own attorney's fees, win or lose," but this general rule can be altered or amended by statute or contract. Hardt v. Reliance Standard Life Ins. Co., 560 U.S. 242, 253 (2010). 

 

As you may recall, the FDCPA authorizes fee shifting, allowing a plaintiff to recover reasonable attorney's fees as determined by the court with costs "in the case of any successful action to enforce the foregoing liability."  15 U.S.C. § 1692k(a)(3).

 

To determine whether such an award was merited here, the Fifth Circuit first turned to the dictionary definition of "successful" — a "favorable outcome," or favorable end result.  Successful, American Heritage Dictionary 1740 (5th ed. 2011); Outcome, Id. at 1251.  "Successful" modifies the word "action" in the statutory language—the "lawsuit" in this case—thus requiring a favorable end or result from a lawsuit, not merely success in vacuo.  Next considering the infinitive phrase "to enforce the foregoing liability," "enforce" expresses the purpose of the "successful action," and thus, the action must succeed in its purpose of enforcing FDCPA liability. 

 

Read together, the Fifth Circuit stated that a "successful action to enforce the foregoing liability" means a lawsuit that generates a favorable end result compelling accountability and legal compliance with a formal command or decree under the FDCPA.

 

Here, the appellate court determined that because settlement was reached before the lawsuit reached any end result, let alone a favorable one, the Debtor won no such relief and the Debt Collector avoided a formal legal command or decree from the lawsuit. 

 

The Debtor argued that his "action" was "successful" because he settled for $1,000, which are the statutory damages allowed by the FDCPA.  The Fifth Circuit rejected this alternative interpretation because it was resolved by settlement agreement that did not "enforce" FDCPA "liability" because it did not compel the Debt Collector to do anything.  Adopting such a position would improperly rewrite Congress's statute to authorize fee-shifting "in the case of any successful plaintiff."

 

The Fifth Circuit also declined to apply the catalyst theory to the FDCPA's fee-shifting provision, as a "successful action[s]" under 15 U.S.C. § 1692k(a)(3) notwithstanding its inapplicability to "prevailing party" statutes.  

 

As you may recall, the catalyst theory posits that a plaintiff succeeds "if it achieves the desired result because the lawsuit brought about a voluntary change in the defendant's conduct" (Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep't of Health & Hum. Res., 532 U.S. 598, 601 (2001)). 

 

The Fifth Circuit declined to adopt that interpretation here because "prevailing party" and "successful party" are synonymous phrases carrying similar legal salience, requiring a formal lawsuit, success in that lawsuit, and some form of judicial relief (as opposed to private relief) that enforces the winner's rights (Prevailing Party, Black's Law Dictionary 1232), and such an interpretation would also disrupt recent circuit precedent and the Supreme Court's mandate that fee-shifting statutes must be interpreted consistently.  Buckhannon, 532 U.S. at 603.

 

Because the Debtor's lawsuit was not a successful FDCPA action as defined by section 1692k(a)(3), the Fifth Circuit held that the trial court correctly determined that he was not entitled to fees, and its denial of attorneys' fees was affirmed.

 

 

 

 

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: 8th Cir Holds No FDCPA Violation When Debt Collector Failed to Meet Its Evidentiary Burden in Collection Lawsuits

The U.S. Court of Appeals for the Eighth Circuit recently affirmed a trial court's dismissal of the plaintiffs' claims in consolidated cases brought under the federal Fair Debt Collection Practices Act (FDCPA) against a debt collector law firm, after the debt collector law firm failed to meet evidentiary burdens in various collection law suits.

 

In so ruling, the Eighth Circuit held that FDCPA "was not meant to convert every violation of a state debt collection law into a federal violation," and a party does not violate the FDCPA by articulating its "good faith legal position" in its "prayer for relief."  Here, (1) the plaintiffs failed to establish that the defendant took anything other than a good faith legal position in its prayer for relief; and (2) the debt collector was entitled to bring a good faith claim to collect alleged debts, despite ultimately not meeting its evidentiary burden in court.

 

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

 

In December 2018, the debt collection law firm filed collection actions on behalf of a creditor against the plaintiffs. The plaintiffs subsequently challenged whether the law firm possessed, or could present evidence establishing, a valid and complete chain of assignment for the alleged debts between the original creditors and the current creditor.

 

The only document the law firm presented to the court was a redacted computer printout that was not the actual attachment to any of the alleged bills of sale. The court agreed with the plaintiffs and dismissed the collection claims for lack of standing.

 

In March 2019, the plaintiffs filed complaints in federal court alleging that the law firm's conduct in bringing the collection actions violated the FDCPA.

 

The plaintiffs first argued that the defendant violated 15 U.S.C. § 1692e by asserting in the Statements of Claim that the plaintiffs owed disbursements without providing evidence of any entitlement to these disbursements or of the intention to seek to recover them. Second, the plaintiffs argued that the law firm violated 15 U.S.C. § 1692f by bringing debt collection lawsuits without sufficient evidence to establish a valid and complete chain of assignment between the original creditors and the current creditor, in violation of the court's Amended Standing Order.

 

The trial court granted the defendant's motion to dismiss both lawsuits. First, the trial court determined that the plaintiffs had failed to state a claim under § 1692e that the defendant used any "false, deceptive, or misleading representations or means" by seeking disbursements in the Statements of Claim. The trial court treated the challenged statements as "the equivalent of the prayer for relief" and further held that the plaintiffs failed to allege any facts that would support a finding that the law firm made the claim for disbursements in bad faith.

 

Second, the trial court concluded that the law firm had not used "unfair or unconscionable" collection means in violation of § 1692f when it failed meet its evidentiary burden to establish standing in court. The trial court reasoned that the FDCPA "was not meant to convert every violation of a state debt collection law into a federal violation" and likewise that the law firm's failure to satisfy the Amended Standing Order's evidentiary standards did not violate the FDCPA. The plaintiffs timely appealed.

 

On review, the Eighth Circuit upheld the trial court's dismissal of the plaintiffs' § 1692e claims. The FDCPA broadly prohibits debt collectors from using "any false, deceptive, or misleading representation or means in connection with the collection of any debt," 15 U.S.C. § 1692e.  When evaluating whether a communication is false, the Eighth Circuit uses an "unsophisticated consumer" standard. Janson v. Katharyn B. Davis, LLC, 806 F.3d 435, 437 (8th Cir. 2015). Additionally, "lawyers who regularly, through litigation, attempt to collect consumer debts" on behalf of their clients are debt collectors governed by the FDCPA. Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA, 559 U.S. 573, 593 (2010).

 

Moreover, a debt collector's representations made to third parties, including courts adjudicating consumer credit lawsuits, may support liability under § 1692e, and the Eighth Circuit takes a "case-by-case" approach in making this determination. See Hemmingsen v. Messerli & Kramer, P.A., 674 F.3d 814, 818-19 (8th Cir. 2012).

 

In Haney v. Portfolio Recovery Assocs., L.L.C., the Eighth Circuit applied Hemmingsen to representations made in a debt-collection complaint's prayer for relief. 895 F.3d at 989. There, the defendant debt collector alleged that the plaintiff debtor owed statutory pre-judgment interest on the accrued contractual interest on the alleged debt. See id. at 979, 987. Even though the Eighth Circuit determined that this "interest-on-interest" was not permitted under Missouri law, the prayer for relief was not a "false, deceptive, or misleading" representation because "the claim for that amount in the petition was a statement directed to the court, and it was a good faith legal position on a point of unsettled Missouri law." Id. at 989.

 

In the present case, the Eighth Circuit agreed with the trial court that the defendant's statements seeking disbursements in the Statements of Claim amounted to a "prayer for relief." The plaintiffs argued that prayers for relief can only be found in a section entitled "Prayer for Relief" or in a "wherefore" clause, but the Court reasoned that the plaintiffs were putting "form over substance." Although the requests appeared toward the beginning of the Statements of Claim, the Court observed that they were directed to the court and were part of the law firm's reasonable request for specific relief.

 

The plaintiffs next argued that the trial court had improperly imposed a new element onto their § 1692e claims by requiring them to plead that the defendant debt collector acted in bad faith when it requested disbursements in the Statements of Claim. However, the Eighth Circuit held that the trial court did not invent a new element and was merely recognizing the principle articulated in Hemmingsen and Haney that, although representations made to third parties (e.g., courts) can be "false, deceptive, or misleading," a party does not violate § 1692e by articulating its "good faith legal position" in its "prayer for relief." Haney, 895 F.3d at 989–90; see Hemmingsen, 674 F.3d at 818–19.

 

The plaintiffs also alleged that there was no possibility of the defendant debt collector recovering disbursements over and above the amount of the alleged debt and the filing fee, and that the defendant debt collector had no intention of seeking to recover any disbursements. However, the Eight Circuit agreed with the trial court's assessment that the defendant debt collector could have recovered disbursements if it had prevailed in the collection action, including to cover the cost-of-service fees, referee's fees, service of documents, certified copies of papers and records in a public office, and witness fees. See Minn. Gen. R. Prac. 516.

 

Therefore, the Court held that the plaintiffs failed to plausibly allege that the defendant made false, deceptive, or misleading representations in violation of § 1692e.

 

The Eighth Circuit also upheld the trial court's dismissal of the plaintiffs' § 1692f claims. The FDCPA prohibits debt collectors from using "unfair or unconscionable means to collect or attempt to collect any debt." 15 U.S.C. § 1692f. "The collection of any amount (including any interest, fee, charge, or expense incidental to the principal obligation)" not "permitted by law" is one such unfair or unconscionable means prohibited by the FDCPA. Id. § 1692f(1).

 

At the time the defendant debt collector filed its collection lawsuits, the court had adopted an Amended Standing Order that provided:

 

10. A party seeking judgment against a consumer on a consumer credit lawsuit shall possess and present to the court:

 

e. admissible evidence establishing a valid and complete chain of assignment of the debt from the original creditor to the party requesting judgment, including documentation or a bill of sale evidencing the assignment with evidence that the particular debt at issue was included in the assignment referenced in the documentation or bill of sale.

 

Ramsey Cnty. Second Jud. Dist., Amended Standing Order, Consumer Credit Case Management Program (Sept. 23, 2016).

 

The plaintiffs argued that the defendant debt collector violated § 1692f(1) because it tried to establish the creditor's standing to sue using evidence (i.e., a redacted computer printout) that did not satisfy the Amended Standing Order.

 

However, the Eighth Circuit noted that the FDCPA "was not meant to convert every violation of a state debt collection law into a federal violation." Klein v. Credico Inc., 922 F.3d 393, 397 (8th Cir. 2019). Although the defendant did not satisfy the Amended Standing Order's evidentiary standard, the Court held that failing to do so was not a violation of § 1692f(1), which is intended to protect consumers from being subjected collection attempts for debts and interest not owed. See Demarais v. Gurstel Chargo, P.A., 869 F.3d 685, 691, 699 (8th Cir. 2017); Haney, 895 F.3d at 987–89. The plaintiffs here do not dispute that the alleged debts are in fact owed.

 

Additionally, the Eighth Circuit has affirmed the dismissal of § 1692f(1) claims where the debt collector sought to collect interest whose availability was at the time legally uncertain. See, e.g., Hill v. Accts. Receivable Servs., LLC, 888 F.3d 343, 346–47 (8th Cir. 2018). Thus, the Court held that the defendant debt collector was entitled to bring a good faith claim to collect the alleged debts, despite failing to meet its evidentiary burden in conciliation court.

 

Accordingly, the Eighth Circuit concluded that the plaintiffs failed to state plausible claims that the defendant made "false, deceptive, or misleading" representations in violation of 15 U.S.C. § 1692e or that the defendant debt collector used "unfair or unconscionable means" to collect debts in violation of 15 U.S.C. § 1692f. Therefore, the Court affirmed the trial court's dismissal of the plaintiffs' claims.

 

 

 

 

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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