Bank of America v. Hallowich

34 Pa. D. & C.5th 276
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedNovember 6, 2013
DocketNo. 10400 of 2013, C.A.
StatusPublished

This text of 34 Pa. D. & C.5th 276 (Bank of America v. Hallowich) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of America v. Hallowich, 34 Pa. D. & C.5th 276 (Pa. Super. Ct. 2013).

Opinion

PICCIONE, J.,

Before this court for disposition are the preliminary objections to the complaint in mortgage foreclosure (hereinafter, the “preliminary objections”) filed on behalf of the defendant, Kurt J. Hallowich (hereinafter, the “defendant”). The current action was commenced on April 22, 2013 when the plaintiff, Bank of America, N.A., Successor by Merger to BAC Home Loans Servicing, LP, F/K/A Countrywide [278]*278Home Loans Servicing, LP (hereinafter, the “plaintiff’), filed the complaint in mortgage foreclosure (hereinafter, the “complaint”), which alleges the defendant defaulted on a mortgage issued by the plaintiffs predecessor in interest. The mortgage encumbers real property the defendant owns in Lawrence County, Pennsylvania. The mortgage was subsequently assigned to the plaintiff. The plaintiff avers in the complaint that the defendant defaulted on the monthly payments of principal and interest upon the mortgage on November 1, 2011, and has failed to render payment each month thereafter. The plaintiff argues that the defendant owes $84,029.49 to the plaintiff as of March 25,2013.

The complaint sets forth that the plaintiff mailed a notice of intention to foreclosure as set forth in Act 6 of 1974 (hereinafter, “Act 6), Notice of Homeowner’s Emergency Mortgage Assistance Program pursuant to Act 91, as amended in 2008, and/or notice of default as required by the mortgage documents as applicable to the defendant. The plaintiff requests in the complaint that this court enter an in rem judgment against the defendant in the sum of $84,029.49 plus interest, costs, fees, and charges collectible under the mortgage.

On May 16, 2013, the defendant filed the instant preliminary objections, wherein the defendant argues that this court is without subject matter jurisdiction due to the plaintiffs failure to comply with the notice requirements of Act 6, Act 91, and/or Pennsylvania Rule of Civil Procedure 1147. Although the complaint alleges that such notices were sent to the defendant, the defendant argues that the plaintiff has not provided any documentation proving that the plaintiff in fact mailed these notices to the defendant. Additionally, the defendant asserts in the preliminary [279]*279objections that the complaint does not comply with Pennsylvania Rule of Civil Procedure 1028(a)(2) because the plaintiff has not provided proper documentation to trace the assignment of mortgage from the initial lender to the plaintiff. Additionally, the defendant argues that the plaintiff has not complied with Rule 1028(a)(2) because the complaint does not provide an itemized statement indicating how the amount allegedly owed was calculated. The defendants request this court dismiss the complaint for these reasons.

The defendant filed a praecipe to place the case for disposition on the preliminary objections, wherein the defendant stated that oral argument was not required. After conferring with each party’s counsel, this court then issued an order dated September 4, 2013 informing the parties that the preliminary objections will be decided on briefs alone and without oral argument. Each party complied with this order and filed its respective brief.

The defendant’s first preliminary objection is in the nature of a demurrer and is based upon violations of Pennsylvania Rule of Civil Procedure 1028(a)(1) and (2). The defendant argues this court is without subject matter jurisdiction because the plaintiff has failed to comply with the notice requirements of Act 6, Act 91, and/or Pa.R.C.P. 1147. The defendant argues that although the complaint alleges that such notices were sent to the defendant, it fails to identify when or to where the notices were sent or provide documentation of the same. Additionally, the defendant argues that even assuming such notices were sent to the defendant, the notices would have been defective. The defendant argues that since the mortgage was modified on March 21, 2013, the plaintiff was required to send an additional Act 6 notice to the defendant thirty days from [280]*280that date before commencing a legal action to collect the debt. Without being provided of such notice, the defendant argues this court lacks subject matter jurisdiction, and the complaint should be dismissed.

The standard of review for a preliminary objection in the nature of a demurrer is as follows:

A preliminary objection in the nature of a demurrer admits as true all well-pled material, relevant facts and every inference fairly deducible from those facts. The pleader’s conclusions or averments of law are not considered to be admitted as true by a demurrer. Since the sustaining of a demurrer results in a denial of the pleader’s claim or a dismissal of his suit, a preliminary objection in the nature of a demurrer should be sustained only in cases that clearly and without a doubt fail to state a claim upon which relief may be granted. If the facts as pleaded state a claim for which relief may be granted under any theory of law, there is sufficient doubt to require the preliminary objection in the nature of a demurrer to be rejected.

Baker v. Central Cambria School Dist., 24 A.3d 488, 492 n.6 (Pa. Cmwlth. 2011) (citing Palmer v. Bartosh, 959 A.2d 508, 512 n.2 (Pa. Cmwlth. 2008) (internal citations omitted)). As stated above, the defendant argues that the plaintiff failed to comply with rule 1028(a)(1) of the rules of civil procedure. Rule 1028(a)(1) provides that a preliminary objection to a pleading may be filed which alleges that the court lacks jurisdiction over the subject matter of the action. Pa.R.C.P. 1028(a)(1).

Prior to commencing the instant proceedings, the plaintiff filed the notice of intention to foreclosure to the defendant. This notice was sent pursuant to the [281]*281requirements of the Act 6, which is codified at 41 RS. § 403. Strict compliance with such notice provisions is a prerequisite of this court’s obtaining subject matter jurisdiction over a mortgage foreclosure action. Bankers Trust Co. v. Foust, 621 A.2d 1054 (Pa. Super. 1993). The plaintiff filed plaintiff’s response to defendant’s preliminary objections (hereinafter, the “response”) in which it asserts that a notice of intention to foreclose mortgage was sent to the defendant at the defendant’s last known address. The plaintiff has attached a copy of the Act 6 notice to its response as exhibit “D.” The court has reviewed the copy and finds that the plaintiff indeed mailed such notice in compliance with Act 6 to the defendant on January 17, 2013.

Both parties recognize that the mortgage was modified by later agreement. Upon review, the court acknowledges that the modification agreement is dated February 10, 2012, and was signed and accepted by the defendant on February 17, 2012. The modification contained material changes to the mortgage. The modification changed the principal sum of the mortgage that is owed to the plaintiff and the date upon which the full amount of the debt is owed to the plaintiff. This modification agreement was recorded in the Recorder’s Office of Lawrence County on March 21, 2013. It appears that the defendant is arguing that he is entitled to receive an additional notice of the intent to foreclosure pursuant to Act 6 after the plaintiff recorded the modification.

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Related

Bankers Trust Co. v. Foust
621 A.2d 1054 (Superior Court of Pennsylvania, 1993)
Poffenberger v. Goldstein
776 A.2d 1037 (Commonwealth Court of Pennsylvania, 2001)
Fish v. Pennsylvania Housing Finance Agency
931 A.2d 764 (Commonwealth Court of Pennsylvania, 2007)
Palmer v. Bartosh
959 A.2d 508 (Commonwealth Court of Pennsylvania, 2008)
Baker v. Central Cambria School District
24 A.3d 488 (Commonwealth Court of Pennsylvania, 2011)
Beckman v. Altoona Trust Co.
2 A.2d 826 (Supreme Court of Pennsylvania, 1938)
Resolution Trust Corp. v. Buchanan
637 A.2d 1020 (Superior Court of Pennsylvania, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
34 Pa. D. & C.5th 276, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-america-v-hallowich-pactcompllawren-2013.