Wells Fargo Bank, N.A. v. Smith

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Appellants lost their home in a foreclosure sale. When Appellants failed to vacate the home, Wells Fargo Bank, the foreclosure purchaser, sued for unlawful detainer. Appellants raised equitable defenses and counterclaims concerning the validity of Wells Fargo's title. Wells Fargo successfully moved to dismiss the defenses and counterclaims on the ground that they exceeded the statutory scope of issues that may be litigated in an unlawful detainer action under Mo. Rev. Stat. 534.210. The circuit court then granted summary judgment to Wells Fargo. Appellants appealed, arguing that section 534.210, which prohibits a defendant from raising equitable defenses and/or challenges to the validity of the plaintiff's title in an unlawful detainer action, was unconstitutional. The Supreme Court affirmed, holding (1) statutory limitations on the scope of unlawful detainer actions are not unconstitutional; and (2) Appellants failed to raise a genuine issue of fact concerning Wells Fargo's right to possession. View "Wells Fargo Bank, N.A. v. Smith" on Justia Law