Bank of New York v. Randolph

CourtCourt of Appeals of South Carolina
DecidedMay 17, 2011
Docket2011-UP-219
StatusUnpublished

This text of Bank of New York v. Randolph (Bank of New York v. Randolph) is published on Counsel Stack Legal Research, covering Court of Appeals of South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bank of New York v. Randolph, (S.C. Ct. App. 2011).

Opinion

THIS OPINION HAS NO PRECEDENTIAL VALUE.  IT SHOULD NOT BE CITED OR RELIED ON AS PRECEDENT IN ANY PROCEEDING EXCEPT AS PROVIDED BY RULE 268(d)(2), SCACR.

THE STATE OF SOUTH CAROLINA
In The Court of Appeals

The Bank of New York, as successor to JP Morgan Chase, N.A., as Trustee on behalf of Certificate-holders and the Certificate Insurer of ABF's Mortgage Loan Trust 2002-1, Mortgage Pass-Through Certificates, Series 2002-1, as successor-in-interest to American Business Mortgage Services, Inc., Appellant,

v.

Robert Earl Salone and Mae B. Randolph, Defendants,

Of Whom Mae B. Randolph is Respondent.


Appeal From Orangeburg County
James C. Williams, Jr., Circuit Court Judge


Unpublished Opinion No.  2011-UP-219 
Submitted March 1, 2011 – Filed May 17, 2011


AFFIRMED


Louis H. Lang, of Columbia, for Appellant.

Zack E. Townsend, of Orangeburg, for Respondent.

PER CURIAM: The Bank of New York (hereinafter Bank) appeals the decision of the trial court granting respondent Mae B. Randolph's motion for voluntary non-suit in regard to Bank's foreclosure action on property held by Randolph as joint tenant with her brother, Robert Earl Salone.  We affirm.[1]

FACTUAL/PROCEDURAL BACKGROUND

The facts of this case are largely undisputed.  In September 1997, Randolph's mother deeded the property in question to Randolph and Salone.  On December 31, 2001, Salone borrowed $25,000 from Bank's predecessor in interest[2] and executed a note in that amount, securing payment with a purported mortgage on the entire property.  However, though Salone signed the mortgage, it is acknowledged that Randolph did not execute the mortgage and her signature on the document was forged by an unknown person at the closing.  It is equally unquestionable that the closing attorney, although directed by the lending institution's closing instructions to procure two forms of identification from the mortgagors, obtained identification only from Salone.  The attorney testified he asked Salone to attain the identification of the other party purporting to be Randolph, but the person did not have the identification at the time of closing.  The closing attorney admitted he did not follow the lending institution's instructions in this regard, and his failure to obtain the proper identification allowed the forgery to occur.

Following institution of this action against Salone and Randolph for foreclosure on the property, Randolph answered and counterclaimed, denying that she executed the mortgage in question, and asserting the lender negligently caused a false document purporting to be a first lien mortgage to be placed on record with a forged signature as a result of the failure to obtain the proper photo identification of the person executing the loan documents.[3]  Randolph also asserted the actions of the lender caused a cloud to be placed upon title to this property.

Randolph testified she never gave her brother permission to mortgage the property, and the first time she knew anything about the mortgage was when she received notice of foreclosure for failure to repay a mortgage.  Randolph further testified that the foreclosure action had caused her to have a bad credit record, and because of this bad credit she was unable to obtain a loan, resulting in the repossession of her automobile.  She also indicated the bad credit rating had resulted in a higher interest rate on her credit card.  At the time of the trial, Bank sought a total of $49,531.82 as the amount owing on the loan.  Randolph stated the value of the home was only about $45,000.  Randolph testified that if Bank were allowed to foreclose on the property, she would not be in a position to outbid Bank.

At the close of Bank's case, Randolph moved for a directed verdict on Bank's foreclosure cause of action, asserting the foreclosure action came about as the result of a "bad" mortgage that would not have occurred had it been known that the party executing the document was not Randolph.[4]    Randolph maintained, because this was a matter in equity, Bank was required to come into the court with clean hands, and Bank should not be allowed to profit from its own negligence and "mis-doings."  Randolph argued she did not obtain any of the money from the loan, yet it affected her one-half interest in the entire property, and the foreclosure action had also ruined her credit.  Bank countered that it had established the debt, the non-payment, and a lien on a one-half interest in the property.  Bank asserted Randolph did not attack the mortgage directly in her answer, but simply asserted causes of action against Bank, and maintained that Bank had "made out a prima facie case for a mortgage foreclosure."  Bank therefore argued the trial judge should order the foreclosure of Bank's lien on one-half interest in the property.

The trial judge noted Randolph was basically asserting Bank's negligence should estop Bank from foreclosing on the property.  After consideration of Randolph's motion for directed verdict, as well as Bank's motion for directed verdict as to Randolph's counterclaims, the trial judge concluded Bank should be denied the right to foreclose on the property, citing the equitable maxim that, where one of two innocent parties must suffer, the law looks with disfavor upon that party who, through due diligence, could have avoided the loss.  In so doing, the trial judge noted Randolph was an innocent party who had no way to protect herself from losing her half interest in the property because she did not have the financial resources to buy out Bank if foreclosure were allowed.  The trial judge further concluded, after reviewing case law on the matter, that the knowledge of the closing attorney was imputed to the lender and therefore knowledge of the closing attorney that closing procedures were not followed as far as obtaining proper identification would be imputed to Bank.  Additionally, the trial judge stated, by the time the lender received the closing papers, it would have known the identification procedure had not been followed, and thus it was on notice of this fact.

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Bank of New York v. Randolph, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-new-york-v-randolph-scctapp-2011.