Angelos v. Maryland Casualty Co.

380 A.2d 646, 38 Md. App. 265, 1977 Md. App. LEXIS 371
CourtCourt of Special Appeals of Maryland
DecidedDecember 12, 1977
Docket331, September Term, 1977
StatusPublished
Cited by13 cases

This text of 380 A.2d 646 (Angelos v. Maryland Casualty Co.) is published on Counsel Stack Legal Research, covering Court of Special Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Angelos v. Maryland Casualty Co., 380 A.2d 646, 38 Md. App. 265, 1977 Md. App. LEXIS 371 (Md. Ct. App. 1977).

Opinion

Lowe, J.,

delivered the opinion of the Court.

The Circuit Court for Calvert County was called upon to determine the priorities to the surplus proceeds from a second mortgage foreclosure sale as between the holder of a third mortgage, Peter Angelos, and a judgment creditor, Maryland Casualty Company. The Angelos’ third mortgage had been executed before, but recorded after, the institution of a suit by Maryland Casualty Company, whose debt had been subsequently reduced to judgment. The court applied the doctrine of lis pendens and awarded the fund to the judgment creditor. Angelos, the third mortgagee, appealed.

A further complication arose after that appeal when the United States of America was permitted by this Court to intervene. The intervenor is asserting tax liens against the surplus from the foreclosure sale by the second mortgagee. The ultimate right to the proceeds depends upon facts not in *267 this record, and while we find the trial court’s judgment to have been in error, we cannot finally determine the full extent of the rights of the parties without further fact-finding.

The initial case which brought on the appeal arose when John and Carolyn DeVaughn, who had come upon bad times, executed to their attorney, Peter Angelos, a third mortgage in the amount of $50,000 as consideration for his legal services. The record is not clear as to whether that consideration was to cover only past services or was intended to include advances for future services. A week after the DeVaughns executed the mortgage, but before Angelos recorded it, Maryland Casualty Company claims to have sued 1 the DeVaughns, presumably under an indemnity agreement for $690,357.00 which Maryland Casualty had apparently paid on account of the DeVaughns under a bonding agreement. A companion suit sought to enjoin the DeVaughns from divesting themselves of their residence, the subsequent sale of which provided the funds under dispute here. 2

*268 The chancellor entered judgment on behalf of Maryland Casualty Company under the doctrine of lis pendens. Lis pendens literally means a pending action; the doctrine derives from the jurisdiction and control which a court acquires over property involved in an action; pending its continuance and until final judgment is entered. Under the doctrine, one who acquires an interest in the property pending litigation relating to the property takes subject to the results of the litigation. It is clear that the doctrine has no application except where there is a proceeding directly relating to the property in question, or where the ultimate interest and object of the proceeding is to subject the property in question to the disposal of a decree of the court. Feigley v. Feigley, 7 Md. 537, 563; see Applegarth v. Russell, 25 Md. 317.

We need not decide the unlikely prospect that the petition for an ex parte injunction to restrain the sale of land preserving an asset for a general creditor was sufficient to comply with the Feigley requisite that the proceeding relate directly to the property in question, since Angelos’ property interest was acquired through a mortgage obtained prior to the commencement of the litigation upon which Maryland Casualty’s lis pendens claim rests, and therefore is not subject to the operation of the doctrine.

Md. Code, Real Prop. Art., § 1-101 (c) defines the term “deed” as used in the Real Property Article to include, among other things, “mortgage”. Subsequent § 3-201 states that:

“Every deed [or mortgage], when recorded, takes effect from its effective date as against the grantor, ... and every creditor of the grantor with or without notice.” (emphasis added).* * 3

Although the mortgage was recorded after the suits were filed, under the statute it took effect against Maryland *269 Casualty as of the date of mortgage, which was (assuming the title report to be correct) nearly a month before the suits were filed.

Maryland Casualty contends, however, that the Angelos mortgage is not a valid mortgage because “there was some question as to what was the consideration for this mortgage in the court below.” The argument that follows is based upon comments made by the chancellor which raised some question as to the validity of the mortgage on the basis of some evidence that part of the consideration may have been for future rather than present services.

“We think there is a substantial question in this case. It is whether this mortgage is valid at all because we apprehend that under the Maryland law a mortgage as argued by Mr. Handen must be given for present consideration and an affidavit to that effect must be entered into. The testimony clearly shows that the mortgage in this case was given in an attempt to secure these attorneys for work which they had done for their clients extending for some period of time in the past and contemplating perhaps some future work but not as much future work as apparently was done.
In any event, we prefer to say that — let’s assume for the purpose of argument that this was a valid mortgage although we have grave doubts about that.”

The chancellor’s reference to the necessity for present consideration in a mortgage, like that of appellee who has parroted him, was apparently misconceived by his contemplation of the law as it existed prior to the legislative amendment in 1972 by Chapter 349. All of the authority they rely upon was predicated upon the old statute and such cases are therefore inapposite in light of the new law presently codified in Real Prop. Art., § 7-102 (b), 4 which reads:

“(b) Priority of future advances. — If after the *270 date of the mortgage or deed of trust, any sum of money is advanced, any endorsement or guaranty is made, or the liability under an indemnity agreement arises, priority for such sum of money or for any indemnity arising under the endorsement, or guaranty, or indemnity agreement dates from the date of the mortgage or deed of trust as against the rights of intervening purchasers, mortgagees, trustees under deeds of trust, or lien creditors, regardless of whether the advance, endorsement, or guaranty was obligatory or voluntary under the terms of the mortgage or deed of trust.”

We can benefit interpretively here from the relatively new legislative procedure of supplying commentary explaining *271 the effect of statutory changes. The extensive comment following that section includes the explanation that:

“The change abolishes the distinction as to whether the advance was obligatory or voluntary under the terms of the mortgage, and makes all future advances date back to the date of the mortgage so as to squeeze out the intervening rights of third parties. ” (emphasis added).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Susquehanna Bank v. United States/Internal Revenue
772 F.3d 168 (Fourth Circuit, 2014)
Julian v. Buonassissi
997 A.2d 104 (Court of Appeals of Maryland, 2010)
Taylor Electric Co. v. First Mariner Bank
992 A.2d 490 (Court of Special Appeals of Maryland, 2010)
Chicago Title Insurance v. Mary B.
988 A.2d 1044 (Court of Special Appeals of Maryland, 2010)
Washington Mutual Bank v. Homan
974 A.2d 376 (Court of Special Appeals of Maryland, 2009)
WESTON BUILDERS & DEVELOPERS, INC. v. McBERRY, LLC
891 A.2d 430 (Court of Special Appeals of Maryland, 2006)
Greenpoint Mortgage Funding, Inc. v. Schlossberg
888 A.2d 297 (Court of Appeals of Maryland, 2005)
DeShields v. Broadwater
659 A.2d 300 (Court of Appeals of Maryland, 1995)
Warfel v. Brady
619 A.2d 171 (Court of Special Appeals of Maryland, 1993)
Permanent Financial Corp. v. Taro
526 A.2d 611 (Court of Special Appeals of Maryland, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
380 A.2d 646, 38 Md. App. 265, 1977 Md. App. LEXIS 371, Counsel Stack Legal Research, https://law.counselstack.com/opinion/angelos-v-maryland-casualty-co-mdctspecapp-1977.