FYI: Fla Sup Ct Holds Note Prevails Over Mortgage in Event of Conflict

The Supreme Court of Florida recently held that a mortgage and note must be read together, and in the event of a conflict, the note prevails, quashing the decision of the Third District Court of Appeal because it conflicted with the Court's established precedent.

 

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

 

Husband and wife applied for a loan as co-borrowers secured by a reverse mortgage on their home, but they did not close on that loan. Instead, a few months later, husband applied for the same type of loan, but as sole borrower.

 

Although only the husband signed the note, both he and his wife signed a "non-borrower spouse ownership interest certification[,]" which identified the husband as the "borrower" and the wife as the "Non-Borrower Spouse."

 

Both parties signed the reverse mortgage. Although the mortgage defined the husband as the "Borrower," it also contained signature lines for both parties at the end "that were preprinted with their names and the word "Borrower."

 

The husband died, which "[a]s with a typical reverse-mortgage loan, … [triggered] acceleration of the debt prior to the repayment date identified in the note and mortgage."

 

The mortgagee at the time then filed a mortgage foreclosure action.  In response, the wife and her two adult children argued that that since she continued to reside at the property as her principal residence, the mortgage could not be foreclosed because "both the note and mortgage conditioned enforcement of the debt on the following: "A Borrower dies and the [mortgaged] Property is not the principal residence of at least one surviving Borrower."

 

The case went to trial and although the trial court ruled that the wife "was not a co-borrower[,] … it denied foreclosure based on a federal statute that governs the insurability of reverse mortgages by the Secretary of the Department of Housing and Urban Development."

 

"On appeal, Florida's Third District Court of Appeals held, on rehearing en banc, that the trial court erred by relying on the federal statute to deny foreclosure because the statute's application 'was neither raised as an affirmative defense … nor litigated by the consent of the parties at the bench trial."

 

However, the Third District then went on to hold "as a matter of law" that the wife was a co-borrower, disagreeing with the trial court on that issue, but nevertheless "affirmed the trial court's denial of foreclosure based on its conclusion that [the bank] failed to establish the occurrence of a condition precedent to its right to foreclose, i.e., that the subject property is not the principal residence of [the wife], a surviving co-borrower under the instant reverse mortgage."

 

The Florida Supreme Court "accepted jurisdiction to resolve the express and direct conflict between the Third District's decision and its prior decisions dating from 1907 and 1934. Reviewing the Third District's decision under the de novo legal standard because the interpretation of notes and mortgages are pure questions of law, the Court concluded that [b]ecause proper application of our precedent establishes that" the wife was not a co-borrower, and reversed the appellate court's ruling.

 

The Supreme Court reasoned that "over one hundred years ago," it "explained why, in foreclosure actions the general rule is that a mortgage should be construed together with the note that it secures…." Simply put, because they were signed as part of the same transaction, the note and mortgage must be read together.

 

The Court went on, reasoning that it has "also long explained that '[t]he general rule is that, if there is a conflict between the terms of a note and mortgage, the note should prevail."

 

The Supreme Court pointed out that both the note and mortgage defined the husband as the "Borrower" and the wife only joined in the mortgage because it "would have been required for the lender to have a valid security interest because the mortgaged property was her homestead," before disagreeing with the Third District's holding that the location of the wife's signature on the mortgage "unambiguously and as a matter of law, … ma[de] her a co-borrower under the mortgage."

 

Because, the Court concluded, "[t]he Third District's holding ignores not only that the mortgage expressly defines [the husband] as the 'Borrower,' but it also ignores that this Court's foreclosure precedent requires courts to read the mortgage together with the note it secures, ... and to look to the note to resolve any conflict, …" it was error to look beyond "the note and mortgage to the other documents that were part of the same transaction to determine, as a matter of law, how the parties intended to define the term 'Borrower.'"

 

Finally, disagreeing with the dissent, the Supreme Court explained that it didn't matter that the Court's foreclosure precedent dealt with "traditional mortgages and therefore should not apply to the reverse mortgage is issue" because "first principles—i.e., the reason for the documents at issue—tell us why we should read a mortgage together with the note it secures regardless of the type of mortgage being foreclosed: '[T]he promissory note, not the mortgage, is the operative instrument in a mortgage loan transaction, since 'a mortgage is but an incident to the debt, the payment of which it secures, and its ownership follows the assignment of the debt.'"

 

 

 

 

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: SCOTUS Expands Upon Spokeo, Requires Standing for Putative Class Members

The Supreme Court of the United States recently held that a plaintiff must suffer a concrete injury resulting from a defendant's statutory violation to have Article III standing to pursue damages from that defendant in federal court.

 

The Court also held that plaintiffs in a class action must prove that every class member has standing for each claim asserted and for each form of relief sought.

 

Justice Kavanaugh wrote the majority opinion, which was joined by Chief Justice Roberts as well as Justices Alito, Gorsuch, and Barrett. Justice Thomas, often considered the Court's most conservative member, wrote a dissent joined by Justices Breyer, Sotomayor, and Kagan. Justice Kagan also wrote a separate dissent that was joined by Justices Breyer and Sotomayor.

 

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

 

BACKGROUND

 

The road to this momentous ruling began at a car dealership where the plaintiff sought to finance the purchase of a vehicle. When running a credit check, the dealership received a TransUnion credit report indicating that the plaintiff's name matched a name on a list of "specially designated nationals" maintained by the United States Department of Treasury's Office of Foreign Assets Control. The OFAC list contains the names of terrorists, drug traffickers, and other serious criminals deemed to be a threat to national security. After seeing his credit report, the dealership refused to sell a car to the plaintiff.

 

The following day, the plaintiff called TransUnion to request a copy of his credit file pursuant to 15 U.S.C. § 1681g(a)(1). TransUnion fulfilled the request and included a copy of the CFPB's summary of rights as required by 15 U.S.C. § 1681g(c)(2). The documents sent to the plaintiff omitted the OFAC alert, so the following day TransUnion sent the plaintiff a second letter explaining that his name potentially matched a name on the OFAC list. However, the second letter did not include the CFPB's summary of rights.

 

THE LAWSUIT

 

The plaintiff subsequently filed suit against TransUnion, asserting three claims under the Fair Credit Reporting Act (FCRA): (1) that in utilizing the OFAC list, TransUnion failed to follow reasonable procedures to ensure the accuracy of information in violation of 15 U.S.C. § 1681e(b); (2) that by omitting the OFAC information from the credit file TransUnion initially mailed to plaintiff in response to his request, TransUnion failed to provide plaintiff with all information in his credit file in violation of § 1681g(a)(1); and (3) that by failing to include another copy of the summary of rights in the second mailing to plaintiff, TransUnion violated § 1681(c)(2).

 

The plaintiff also asserted those three claims on behalf of a class of all people in the United States to whom TransUnion mailed a follow-up OFAC notice without a summary of rights — i.e., those who received a mailing like the second mailing received by the plaintiff. There were 8,185 people in the class, but only 1,853 of them had their credit reports sent to creditors during the relevant time period.

 

The plaintiff prevailed on all three claims at trial and the jury awarded over $60 million ($984.22 in statutory damages and $6,353.08 in punitive damages for each member of the class). On appeal, the Ninth Circuit agreed that all members of the class had Article III standing, but reduced the punitive damages award to just under $4,000 per class member, which brought the overall award to roughly $40 million.

 

The Supreme Court granted certiorari.

 

SCOTUS DECISION

 

The Supreme Court's opinion focused on whether each member of the class suffered a "concrete" injury and further developed its analysis of concreteness provided five years earlier in Spokeo, Inc. v. Robins, 578 U.S. 330 (2016).

 

In particular, the Court elaborated on the limits of Congress's power to create statutory injuries that can form the basis of a lawsuit in federal court. After all, as the Court held in Spokeo, "Article III requires a concrete injury even in the context of a statutory violation." And this means that "[o]nly those plaintiffs who have been concretely harmed by a defendant's statutory violation may sue that private defendant over that violation in federal court."

 

In further describing those Congressional limits, the Court cited recent FDCPA decisions from the Seventh and Eleventh Circuits. The Court agreed with the Eleventh Circuit (Trichell v. Midland Credit Mgmt., Inc., 964 F.3d 990, 999, n. 2 (11th Cir. 2020)) that Congress's "say so" does not make an injury concrete. The Court also quoted the Seventh Circuit opinion written by then-Judge (now Justice) Barrett in Casillas v. Madison Avenue Assocs., Inc., 926 F. 3d 329, 332 (7th 2019) to explain that "'Article III grants federal courts the power to redress harms that defendants cause plaintiffs, not a freewheeling power to hold defendants accountable for legal infractions.'" 

 

In determining whether the class members had standing, the Court examined whether the alleged injury bore a "close relationship to a harm traditionally recognized as providing a basis for a lawsuit in American courts," here the harm to one's reputation resulting from defamation.

 

Starting with the 1,853 class members whose credit reports were disseminated to creditors, the Court noted that American law has long recognized that a person is injured when a defamatory statement is published to a third party. Therefore, class members whose credit reports were published to third parties were injured because those reports flagged them as potential terrorists.

 

Although the credit reports merely alerted users to a potential match on the OFAC list and did not falsely assert that any class member was a terrorist, the Court held that the harm associated with being described as a potential terrorist bears a sufficiently close relationship to being called a terrorist. Therefore, the Court affirmed the finding of standing on the § 1681e(b) claim for the plaintiff and the 1,853 members of the class whose credit reports were disseminated by TransUnion.

 

The SCOTUS then turned to the 6,332 class members whose credit reports were not disseminated and questioned whether they suffered a concrete injury from the mere existence of an inaccurate credit file that was never published to a third party. The Court determined that publication is necessary for a concrete injury, comparing an unpublished credit report with a defamatory letter that is hidden in a desk drawer instead of mailed.

 

The Court also rejected the plaintiff's argument that all class members had standing because they were subjected to a material risk of future harm based on the potential later release of their credit reports. The Court's prior decision in Spokeo noted that a risk of future harm can sometimes satisfy the concreteness requirement, so long as the risk is sufficiently imminent and substantial.

 

In Ramirez, the Court took the opportunity to explain that a plaintiff exposed to a risk of future harm may sometimes have standing to pursue injunctive relief to prevent that harm from occurring, but a mere exposure to risk is insufficient to confer standing to seek retrospective damages. Because their credit reports were never published, the Court reversed the finding of standing for the other 6,332 class members on the § 1681e(b) claim.

 

The SCOTUS then addressed whether the class members had standing to pursue what it called the "disclosure claim" (based on the omission of OFAC information from the credit file sent to class members pursuant to § 1681g(a)) and the "summary-of-rights claim" (based on the failure to send another summary of rights with the follow-up mailing that contained the OFAC information).

 

The plaintiff argued that all class members suffered a concrete injury because they were deprived of their right to receive information in the format required by the FCRA, but the Court rejected this argument because there was no evidence that any class member suffered a harm that bore a close relationship with a harm traditionally recognized as providing a basis for a lawsuit in American courts. Indeed, there was no evidence that anyone other than the plaintiff himself even opened the two mailings, much less that anyone acted or failed to act based on the information contained in those mailings.

 

Although Congress can elevate to legally cognizable the harm associated with the denial of information subject to public disclosure, the Court again cited Casillas and Trichell in pointing out that the FCRA, like the Fair Debt Collection Practices Act, is not a public-disclosure law.

 

The Court then turned to Trichell once more in noting the failure to identify any "downstream consequences" resulting from the defective disclosures: "An 'asserted informational injury that causes no adverse effects cannot satisfy Article III.'" Therefore, the Court held that none of the class members had standing to pursue damages for the "disclosure claim" or the "summary-of-rights claim."

 

IMPACT ON CONSUMER LITIGATION

 

In the wake of Spokeo, the federal circuit and district courts were divided on whether a statutory violation, on its own, was sufficient to confer standing. For example, the Sixth Circuit in Macy v. GC Services Ltd. Partnership, 897 F.3d 747 (6th Cir. 2018), held that an alleged violation of a disclosure provision of the FDCPA was itself enough to confer standing, a holding that was expressly rejected by the Seventh Circuit in Casillas. The Supreme Court's ruling in Ramirez appears to resolve this split and essentially makes Casillas and Trichell the law of the land.

 

Going forward, plaintiffs who merely allege a technical violation of a consumer-protection statute, with no associated concrete injury, lack standing to pursue that claim in federal court. Also, even if the plaintiff can prove that he suffered a concrete injury as the result of a statutory violation, he or she will be unable to represent a class unless he or she can also prove that every putative class member suffered a concrete injury as well.

 

In other words, gone are the days in which a plaintiff could pursue class recovery based solely on the fact that every member of the class received the same allegedly defective letter.

 

In his dissent, Justice Thomas notes that the Ramirez decision gives defendants like TransUnion more than they bargained for because consumers are often able to pursue violations of federal statutes in state court and defendants will be unable to remove those cases to federal court when the plaintiff lacks Article III standing.

 

For cases now pending in federal court that are subject to dismissal due to lack of standing, defendants should evaluate whether those cases can be filed again in state court. Some states have savings statutes that extend the time to file if the limitations period expired while the case was pending in federal court. Other states lack savings statutes or have savings statutes that apply only in limited situations.

 

Also, because many cases will undoubtedly be filed in state court going forward, defendants should familiarize themselves with the standing doctrines applied in various state courts.

 

 

 

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: CFPB Issues Final Rule on Mortgage Servicing for Borrowers Affected by COVID-19

The federal Consumer Financial Protection Bureau (CFPB) recently issued its final rule entitled "Protections for Borrowers Affected by the COVID-19 Emergency Under the Real Estate Settlement Procedures Act (RESPA), Regulation X".

 

The Final Rule is available at:  Link to Final Rule

 

The Final Rule becomes effective on August 31, 2021.  Of note, the federal foreclosure and eviction moratoria expire on July 31, 2021.

 

The Final Rule announcement cites a number of data points, including from private industry sources and from its own studies.  For example, the CPFB notes that "[a]s of April 2021, there were still an estimated 1.9 million borrowers in forbearance programs who were more than 90 days behind on their mortgage payments," and that "[w]hile the national delinquency rate fell to 4.66 percent in April, it remains about 1.5 percent above its pre-pandemic level."

 

In summary, and among other things, the Final Rule provides:

 

A.  Limitations on Foreclosure Starts

 

The Final Rule only applies when:  (1) the foreclosure process is started on August 31, 2021 through and including December 31, 2021; and  (2) “the borrower’s mortgage loan obligation became more than 120 days delinquent on or after March 1, 2020”; and  (3) “The statute of limitations applicable to the foreclosure action being taken in the laws of the State or municipality where the property securing the mortgage loan is located expires on or after January 1, 2022.”

 

Stated differently, from August 31, 2021 to December 31, 2021, a mortgage servicer may start a judicial or non-judicial foreclosure process based on a payment default without the necessity to follow the new CFPB Final Rule only if:  (1) the borrower’s mortgage loan obligation became more than 120 days delinquent before March 1, 2020;  or  (2) the statute of limitations applicable to the foreclosure action being taken in the laws of the State or municipality where the property securing the mortgage loan is located expires before January 1, 2022.

 

Then, if the Final Rule applies, the servicer may proceed with foreclosure, if: (1) “the borrower submitted a completed loss mitigation application and [existing 12 CFR] § 1024.41(f)(2) permits the servicer to make the first notice or filing;” or (2) “the property securing the mortgage loan is abandoned under State or municipal law;” or (3) “the servicer has conducted specified outreach and the borrower is unresponsive.”

 

B.  Provisions for Incomplete Loan Modification Applications

 

Subject to specified criteria, the Final Rule "permits servicers to offer certain streamlined loan modification options made available to borrowers with COVID-19-related hardships based on the evaluation of an incomplete loss mitigation application" 

 

"If the borrower accepts an offer made pursuant to this new exception," the Final Rule temporarily "excludes servicers from certain requirements with regard to any loss mitigation application submitted prior to the

loan modification offer, including exercising reasonable diligence to complete the loss mitigation application and sending the acknowledgement notice required by [existing 12 CFR] § 1024.41(b)(2)."

 

C.  Communicating Additional COVID-19 Information and Options

 

The Final Rule "requires servicers to discuss specific additional COVID-19-related information during live contact with borrowers established under existing [12 CFR] § 1024.39(a)" in circumstances where "the borrower is not in a forbearance program", or "the borrower is near the end of a forbearance program made available to borrowers experiencing a COVID-19 related hardship."

 

D.  "Reasonable Diligence" Obligations for COVID-19 Forbearances

 

The Final Rule also "clarifies servicers' reasonable diligence obligations when the borrower is in a short-term payment forbearance program made available to a borrower experiencing a COVID-19-related hardship based on the evaluation of an incomplete application."

 

The "servicer must contact the borrower no later than 30 days before the end of the forbearance period if the borrower remains delinquent to determine if the borrower wishes to complete the loss mitigation application and proceed with a full loss mitigation evaluation", and "must exercise reasonable diligence to complete the application before the end of the forbearance program period" if the borrower requests further assistance.

 

E.  "COVID-19-Releated Hardship"

 

Lastly, the Final Rule provides that a "COVID-19-related hardship" means "a financial hardship due, directly or indirectly, to the national emergency for the COVID-19 pandemic declared in Proclamation 9994 on March 13, 2020 (beginning on March 1, 2020) and continued on February 24, 2021, in accordance with section 202(d) of the National Emergencies Act (50 U.S.C.1622(d))".

 

 

 

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: 6th Cir Holds Even "Bad Faith" Chpt 13 Bankruptcy Must Be Dismissed On Request by Debtor

The U.S. Court of Appeals for the Sixth Circuit recently held that 11 U.S.C. § 1307(b) requires a bankruptcy court to dismiss a Chapter 13 bankruptcy petition upon a debtor's request, even if the debtor filed his or her petition in bad faith.

 

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

 

In 2004, debtor ("Debtor") obtained $528,500.00 loan ("Loan") to purchase a home ("Property").  About one year later, Debtor defaulted on the Loan resulting in the mortgage holder scheduling the Property's foreclosure sale for August 7, 2007. 

 

In order to prevent the foreclosure sale from going forward, Debtor filed for Chapter 13 Bankruptcy thereby triggering the automatic stay provided by 11 U.S.C. § 362(a).  Debtor dismissed his Chapter 13 case after the August 7, 2007 foreclosure sale date passed. 

 

In 2017, the mortgage holder again scheduled the Property's foreclosure sale, and Debtor once again filed a Chapter 13 Bankruptcy petition. After the Property's foreclosure sale date passed, Debtor dismissed his Chapter 13 petition.

 

In early 2019, the appellee bank ("Bank") purchased the Loan and subsequently set the Property's foreclosure sale for February 19, 2019.  On the day before the foreclosure sale, Debtor filed a third Chapter 13 petition again obtaining an automatic stay preventing the foreclosure sale from moving forward. Debtor dismissed his Chapter 13 petition six days later, which the bankruptcy court granted (the "Dismissal").

 

In June 2019, the bankruptcy court: (1) granted the Bank's motion to vacate the Dismissal pursuant to Fed. R. Civ. P. 60(b); and (2) separately lifted the automatic stay that would have prevented the Property's foreclosure sale. 

 

Debtor appealed to the district court seeking a stay of the bankruptcy court's reinstatement of his Chapter 13 petition.  The district court denied Debtor's request for a stay but certified for interlocutory appeal "the question whether the reinstatement of [Debtor's Chapter 13 petition] was contrary to law." 

 

The Sixth Circuit granted Debtor leave to file the instant appeal.

 

On appeal, the Sixth Circuit was tasked with determining "the legality of the bankruptcy court's June 2019 order reinstating [Debtor's] Chapter 13 case."  As you may recall, 11 U.S.C. § 1307(b) ("Section 1307") provides that "[o]n request of the debtor at any time, if the case has not been converted [from a case under Chapter 7, 11, or 12], the court shall dismiss a case under this chapter."

 

In analyzing Section 1307, the Sixth Circuit noted that upon a debtor's request for dismissal, "the court shall dismiss a Chapter 13 case." 

 

In response, the Bank argued that dictum from Marrama v. Citizens Bank of Massachusetts, 549 U.S. 365 (2007) ("Marrama"), allows a bankruptcy court to deny a debtor's motion to dismiss a Chapter 13 case if the debtor filed his or her petition in bad faith.

 

However, the Sixth Circuit rejected the Bank's argument explaining that the Supreme Court of the United States rejected the Marrama dictum in Law v. Siegel, 571 U.S. 415 (2014), explaining that "[a]t most, Marrama's dictum suggests that in some circumstances a bankruptcy court may be authorized to dispense with futile procedural niceties in order to reach more expeditiously an end result required by the Code." Id. at 426. 

 

In finding that Section 1307 is "no mere procedural nicety," the Sixth Circuit rejected the Bank's reliance on Marrama. 

 

Next, the Bank argued that Fed. R. Civ. P. 60(b)(3) allows the bankruptcy court to vacate its dismissal of Debtor's Chapter 13 Petition.  However, the Sixth Circuit disagreed stating that Section 1307 mandates a bankruptcy court dismiss a Chapter 13 case upon a debtor's request and "[Section 1307's] command would be meaningless if a bankruptcy court could then vacate its dismissal under [Fed. R. Civ. P. 60(b)]."

 

Thus, the Court held the district court abused its discretion in finding that the bankruptcy court could reinstate Debtor's Chapter 13 case under Fed. R. Civ. P. 60(b).

 

Accordingly, the Sixth Circuit reversed the district court's order denying Debtor's motion for a stay and further remanded this matter with instructions that the bankruptcy court must dismiss Debtor's Chapter 13 petition.   

 

 

 

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.

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

 

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and

 

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