21st Mortgage Corporation v. Raymond Robinson (Appeal from Baldwin Circuit Court: CV-19-900109).

CourtSupreme Court of Alabama
DecidedDecember 20, 2024
DocketSC-2023-0304
StatusPublished

This text of 21st Mortgage Corporation v. Raymond Robinson (Appeal from Baldwin Circuit Court: CV-19-900109). (21st Mortgage Corporation v. Raymond Robinson (Appeal from Baldwin Circuit Court: CV-19-900109).) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
21st Mortgage Corporation v. Raymond Robinson (Appeal from Baldwin Circuit Court: CV-19-900109)., (Ala. 2024).

Opinion

Rel: December 20, 2024

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is printed in Southern Reporter.

SUPREME COURT OF ALABAMA OCTOBER TERM, 2024-2025

_________________________

SC-2023-0304 _________________________

21st Mortgage Corporation

v.

Raymond Robinson

Appeal from Baldwin Circuit Court (CV-19-900109)

SHAW, Justice.

21st Mortgage Corporation ("21st Mortgage"), the defendant below,

appeals from a judgment on a jury verdict in favor of Raymond Robinson SC-2023-0304

("Robinson"), the plaintiff below, on Robinson's claims alleging

promissory fraud and the tort of outrage. We reverse and remand.

Facts and Procedural History

In January 2019, Robinson and his son, Raymond G. Robinson, Jr.

("Raymond"), sued, in the Baldwin Circuit Court, Emerald Homes, L.L.C.

("Emerald"), a mobile-home dealer located in Baldwin County, and 21st

Mortgage, a Tennessee-based mobile-home mortgage lender. According

to the complaint, Robinson had resided in a house situated on property

that he and Raymond jointly owned in Gulf Shores. In December 2016,

Robinson contracted with Emerald for the purchase of a mobile home to

replace the existing house on the property, which purchase he attempted

to finance by means of a loan from 21st Mortgage. Thereafter, Robinson

tore down his house in preparation for the delivery of his new mobile

home, an event that ultimately did not occur because, Robinson also

alleged, Emerald and/or 21st Mortgage refused to complete the loan

transaction.

The complaint, filed by both Robinson and Raymond, asserted the

following causes of action against both Emerald and 21st Mortgage:

breach of contract, "misrepresentation," suppression, and "negligence,

2 SC-2023-0304

wantonness and/or outrageous misconduct." Robinson and Raymond

sought to recover both compensatory and punitive damages. The trial

court compelled arbitration of Robinson and Raymond's claims against

Emerald. The trial court later entered a summary judgment in favor of

21st Mortgage on all of Raymond's claims. Thereafter, the matter

proceeded to a jury trial solely on Robinson's remaining claims against

21st Mortgage.

According to the testimony of John Leath, Emerald's general

manager at all relevant times, in late 2016 Robinson was interested in

and attempted to purchase a new mobile home from Emerald. Emerald

forwarded Robinson's financing application package to 21st Mortgage.

21st Mortgage denied that initial application the following day based on

its conclusion that Robinson's income was insufficient to support the

requested loan amount; however, it indicated that it would consider

financing a lesser amount. Based on Emerald's reduction of the price of

the mobile home, the inclusion of some additional income earned by

Robinson, a proposed $4,000 down payment, and the contents of

Robinson's then-current credit report, 21st Mortgage subsequently

issued, on or around November 30, 2016, a "Pre-Approval Notice." The

3 SC-2023-0304

preapproval notice expired, according to its terms, on January 29, 2017.

It further referenced and was accompanied by certain "loan conditions."

While some of the conditions indicated that they must be satisfied before

closing (these are referred to in the record as the "closing conditions"),

four were specified as "Required Before Funding Loan": providing

verification of Robinson's down payment to Emerald by certified funds,

providing a copy of his Social Security card, providing proof that any

mortgage on the property had been paid in full, and providing a copy of

the deed establishing his ownership of the property. These are referred

to in the record as the "funding conditions." The preapproval notice also

included the following language: "A change in loan amount, type of loan

product, equity position, credit score, repayment ability, term, or the

inability to satisfactorily provide or comply with the Remaining Loan

Conditions as itemized in this letter could result in a higher interest rate

or inability to qualify." (Emphasis added.)

On December 28, 2016, Robinson and Emerald executed a purchase

agreement for the mobile home upon Emerald's receipt of Robinson's

certified check for the down payment in the amount of $4,000.

Thereafter, 21st Mortgage completed, at Emerald's request and before

4 SC-2023-0304

the preapproval expiration date, several "relooks" at Robinson's

application, which resulted in minor adjustments to his financing terms

and to updated preapproval notices. For instance, a " relook" by 21st

Mortgage at Robinson's application on January 19, 2017, slightly

increased Robinson's required down-payment amount to $4,058.

However, the "loan conditions" and expiration date contained in the

original preapproval notice never changed, including the warning that

the failure to comply with the loan conditions or a change in Robinson's

credit history could result in a denial of financing.

Additional instructions from 21st Mortgage dated January 23,

2017, requested proof of Robinson's income, proof of Robinson's payment

of the increased down-payment amount of $4,058, and a clear photocopy

of Robinson's identification. In response, Emerald provided income

verification and copies of Robinson's driver's license and Social Security

card. On January 25, 2017, in response to a request generated by 21st

Mortgage the previous day, Emerald also provided a copy of Robinson's

2015 tax return and a letter bearing his signature, which read as follows:

" To whom it may concern, This letter is to verify that my previous home

was demolished and removed from [my] property…. I do not have an

5 SC-2023-0304

open mortgage for the above-mentioned property." According to Leath,

at that point Emerald had purportedly provided all requested

information and Robinson's loan was "[r]eady to close." 1

As of January 25, 2017, 21st Mortgage agreed that Robinson had

satisfied all of its "closing conditions." Thus, despite the fact that it still

needed to verify his "down payment [of] $4,058; proof of current home

sold [sic]; and copy of the deed," at that time, Lisa Ryan, the 21st

Mortgage credit manager in charge of Robinson's file, made an entry on

Robinson's application indicating that it needed a valuation report -- a

federally mandated notice prepared by a third party, which provides the

proposed customer with a three-day waiting period to review the mobile

home that is the subject of a pending financing application. The

valuation report was issued on January 26, 2017. Based on that date,

according to representatives of 21st Mortgage, the earliest that

Robinson's loan could have closed was January 30, 2017 -- one day after

the preapproval period expired. Although 21st Mortgage had an internal

1Leath maintained that the remaining extra $58 due from Robinson

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