Pioneer Builders Co. of Nev., Inc. v. KDA Corp.

Pioneer Builders financed the purchase of an RV park (Property). At that time, the Property was subject to several existing recorded and unrecorded leases. When Pioneer attempted to foreclose on the property, some of the owners of the unrecorded leases (Defendants) argued that Pioneer could not foreclose on their lots because their interests in the Property were superior to Pioneer's. The district court found that, although Pioneer was entitled to foreclose on its loans, Pioneer had actual and constructive notice of the unrecorded leases. Accordingly, the court concluded that Pioneer's interest in the Property was inferior to the interests of the Defendants. The Supreme Court reversed the district court's grant of summary judgment in favor of Defendants, holding that the district court applied an incorrect legal standard regarding constructive notice and conflated the issue of whether Pioneer had notice of any recorded leases with whether it had notice of the unrecorded leases at issue. Remanded. View "Pioneer Builders Co. of Nev., Inc. v. KDA Corp." on Justia Law