Justia Banking Opinion SummariesArticles Posted in Minnesota Supreme Court
Hansen v. U.S. Bank National Ass’n
The Supreme Court reversed the decision of the court of appeals affirming the district court's dismissal of Appellants' complaint against U.S. Bank on statute of limitations grounds, holding that Appellants' breach of fiduciary duty claim was timely.On January 24, 2017, Appellants filed their lawsuit, alleging breach of fiduciary duty and unjust enrichment. U.S. Bank moved to dismiss the claim, arguing that Appellants failed to satisfy the applicable six-year statute of limitations. In response, Appellants asserted that they had suffered no damages earlier than August 2012. The district court granted the motion to dismiss, concluding that Appellants could have raised their claims in April 2010. The court of appeals affirmed, concluding that "some damage" occurred on April 27, 2010. The Supreme Court reversed, holding that U.S. Bank failed to establish - based on the pleadings - that Appellants suffered "some damage" in the form of financial harm before August 2012, and therefore, the district court erred by granting the motion to dismiss. View "Hansen v. U.S. Bank National Ass'n" on Justia Law
Big Lake Lumber, Inc. v. Sec. Prop. Invs., Inc.
Mark Hilde hired Big Lake Lumber (Big Lake), Wruck Excavating (Wruck), and J. DesMarais Construction (DesMarais) to help him build a "spec home." 21st Century Bank (Bank) recorded a mortgage against the property to finance the purchase of the property and the home construction. After the Bank foreclosed on its mortgage, Big Lake commenced this mechanic's lien foreclosure action. The district court found that the mechanic's liens of Big Lake and DesMarais related back to the date Wruck commenced work on the improvement project, and thus, the mechanic's liens of Big Lake and DesMarais had priority over the mortgage of the Bank. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred by adopting and then applying a new "integrated analysis" to find the Bank's mortgage superior to the liens; and (2) the district court did not clearly err when it found that Wruck, Big Lake, and DesMarais contributed to the same project of improvement, and accordingly, under the relation-back doctrine, the mechanic's liens of Big Lake and DesMarais had priority over the Bank's mortgage. View "Big Lake Lumber, Inc. v. Sec. Prop. Invs., Inc." on Justia Law
Marine Credit Union v. Detlefson-Delano
Respondent credit union sought to foreclose on the homestead that Appellant and her husband (Husband) owned. The district court granted summary judgment to Appellant after concluding that the mortgage Appellant signed with Respondent was void under Minn. Stat. 507.02 because it was not also signed by Husband. The court of appeals reversed, concluding that the mortgage was valid because Husband had quitclaimed all of his interest in the homestead property to Appellant before the mortgage was executed. The Supreme Court reversed, holding that the mortgage signed by Appellant in favor of Respondent was void because (1) the mortgage at issue here did not meet any of the statutory exceptions to the signature requirement in section 507.02; and (2) Husband's quitclaim deed did not constitute an explicit waiver of his rights under the homestead statute. View "Marine Credit Union v. Detlefson-Delano" on Justia Law
Ruiz v. 1st Fidelity Loan Servicing, LLC
1st Fidelity Loan Servicing initiated a foreclosure by advertisement to collect the debt secured by a mortgage on the home of Respondent. 1st Fidelity subsequently purchased the property at the foreclosure sale. Respondent filed a complaint seeking a declaration that the sale was null and void and the recovery of monetary damages, alleging that 1st Fidelity failed to comply with certain statutory requirements. The district court granted summary judgment in favor of 1st Fidelity on the ground that it had substantially complied with the relevant statutes. The court of appeals reversed, concluding that Minnesota's foreclosure by advertisement statute requires strict compliance and that a foreclosing party's failure to strictly comply renders the foreclosure void. The Supreme Court affirmed, holding (1) a party must strictly comply with Minn. Stat. 580.02(3), which requires that all assignments of a mortgage be recorded before a party is entitled to make a foreclosure by advertisement; and (2) because 1st Fidelity did not strictly comply with section 580.02(3), the foreclosure was void. Remanded. View "Ruiz v. 1st Fidelity Loan Servicing, LLC " on Justia Law
Weavewood, Inc. v. S & P Home Invs., LLC
At issue in this dispute over a mortgage was whether statutes of limitations apply to actions for declaratory judgment. The court of appeals reversed in part the district court's grant of summary judgment to Defendant based on the applicable statute of limitations, holding that to the extent Plaintiff's complaint sought declaratory relief, it was not barred by the statute of limitations. The Supreme Court reversed, holding that because the Uniform Declaratory Judgments Act is a procedural device through which parties may vindicate substantive legal rights, an action for declaratory judgment is barred by an applicable statute of limitations to the same extent that the same cause of action would be barred in a nondeclaratory proceeding. Remanded. View "Weavewood, Inc. v. S & P Home Invs., LLC" on Justia Law
Hardin County Savings Bank v. City of Brainerd Hous. & Redevelopment Auth.
Six banks (the Banks) alleged that the negligent misrepresentation of Respondent, James H. Bedard, Inc., caused them to be damaged when the Housing and Redevelopment Authority of the City of Brainerd defaulted on bonds held by the Banks. Specifically, the Banks purchased $3.3 million in bonds from the City, which helped finance a development project in the City. In deciding to purchase the bonds, the Banks relied on an appraisal and feasibility study prepared by Bedard. The Banks filed a negligent misrepresentation claim against Bedard, alleging that Bedard's study overstated the value of the project and the rate at which the land would sell. The district court dismissed the action, concluding that the Banks failed to plead their negligent misrepresentation claim against Bedard with particularity. The court of appeals affirmed. The Supreme Court reversed, holding that because the Banks specifically pleaded facts underlying each of the elements of their negligent misrepresentation claim, the Banks pleaded the "ultimate facts" of their claim and thus satisfied the particularity requirement under Minn. R. Civ. P. 9.02. Remanded. View "Hardin County Savings Bank v. City of Brainerd Hous. & Redevelopment Auth." on Justia Law
Eclipse Architectural Group, Inc. v. Lam
This case involved two mechanic's liens foreclosed against a hotel property. An agent of the lien claimants personally served mechanic's liens statements on the property owner. Appellant, a community bank, challenged the validity of this service. Appellant argued that a lien claimant may not personally serve a mechanic's lien statement, and therefore, service was improper. As a result, Appellant contended that the mechanic's liens were invalid and could not be foreclosed. The district court determined that service was proper and entered judgment in favor of the lien claimants. The court of appeals affirmed. The Supreme Court affirmed, holding that a lien claimant may personally serve a mechanic's lien statement, and therefore, service of the mechanic's lien statements in this case was proper. View "Eclipse Architectural Group, Inc. v. Lam" on Justia Law