Brown v. Bank of America

34 Pa. D. & C.5th 507
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedNovember 22, 2013
DocketNo. 10652 of 2013, C.A.
StatusPublished

This text of 34 Pa. D. & C.5th 507 (Brown v. Bank of America) 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
Brown v. Bank of America, 34 Pa. D. & C.5th 507 (Pa. Super. Ct. 2013).

Opinion

MOTTO, P.J.,

Before the court for disposition are the preliminary objections of the defendant Bank of America to plaintiff’s complaint in the nature of a demurrer pursuant to Pa.R.C.P. 1028(a) (4). Defendant contends that plaintiff’s action is barred by the doctrine of res judicata because it involves the same action and parties as were involved in the foreclosure proceedings at case captioned Bank of New York, as trustee for certificate holders of CWMBS 2003-R4 v. Judy D. Brown, Case No. 11365 of 2007, C.A., Lawrence County, as well as the same action and parties that were involved in magisterial district court proceedings in Lawrence County at no. CV-85-13. Because this court concludes that plaintiff’s complaint constitutes an impermissible collateral attack on the final judgment entered in the foreclosure proceedings at Case No. 11365 of 2007, C.A. and all the necessary elements required for the doctrine of res judicata to apply are present, the court will sustain the [509]*509defendant’s preliminary objection and dismiss plaintiff’s complaint with prejudice.

In general, plaintiff’s complaint alleges acts of impropriety by defendant Bank of America, relative to a mortgage loan contract with plaintiff as mortgagor which ultimately resulted in foreclosure proceedings at Case No. 11365 of 2007, C.A. Count I of the complaint alleges that defendant engaged in fraud, misrepresentation and deceptive business practices by inflating the value of her property to qualify for a FHA loan; utilizing a notary who notarized documents without the signer of the document being present before the notary; retaining the Phelan, Hallinan and Schmeig law firm to pursue foreclosure using fraudulent loan documents and providing an address in Plano, Texas that is actually a processing center; and further alleging that defendant “pushed loan through direct endorsements system” knowing it didn’t qualify. In count II of the complaint, plaintiff alleges a breach of contract contending that defendant placed a mortgage upon her property even though the property was not titled as real estate and did not qualify for FHA financing and otherwise in failing to follow FHA regulations when foreclosing upon the real estate.

The proceedings at Case No. 11365 of 2007, C.A. constitute a foreclosure action based upon the same mortgage which is the subject of the proceedings in the instant action. In that proceeding the defendant failed to respond to the complaint with the result that a default j udgment was entered against her. Approximately five years after the entry of the default judgment plaintiff engaged in filing a series of motions and petitions seeking to contest, and ultimately, to open or set aside that judgment, which were unsuccessful. Aside from the proceedings filed at [510]*510the foreclosure action itself, plaintiff filed a complaint against Bank of America in the magistrate district court in Lawrence County at Case Number CV-85-13 alleging similar claims related to her mortgage which action was dismissed by the district court judge.

Initially, the court will examine the propriety of addressing the affirmative defense of res judicata through preliminaiy objections. Pa.R.C.P. 1030 contemplates that all affirmative defenses, including res judicata, shall be pleaded in a responsive pleading under the heading of “new matter”. Ordinarily a court may not take judicial notice in one case of the record in another case even though the case arose in the same court and the contents of those records are known to the court. Callery v. Municipal Authority of Blythe Twp., 432 Pa. 307, 243 A.2d 385 (1968). However, if the circumstances necessary to sustain the plea of res judicata appear on the face of the complaint, the defense may be raised by preliminary objections. Jones v. Costlo, 354 Pa. 245, 47 A.2d 259 (1946) cited in Callery v. Municipal Authority of Blythe Twp., 432 Pa. at 307, 243 A.2d 385. (1968). However, if the circumstances necessary to sustain the plea of res judicata appear on the face of the complaint, the defense may be raised by preliminary objections. Jones v. Costlo, 354 Pa. 245, 47 A.2d 259 (1946) cited in Callery v. Municipal Authority of Blythe Twp., 432 Pa. at 310, 243 A.2d at 387. In Flemming v. Strayer, 367 Pa. 284, 80 A.2d 786 (1951), also cited by the Callery court, the original complaint referred to the prior action. The complaint was then amended to delete any reference to the prior suit. The Supreme Court held that the admission of the existence of the prior judgment still appeared on the face of the record and permitted the defendant to assert a res judicata defense by preliminary objection.

[511]*511Here, plaintiff has specifically referenced the prior foreclosure proceedings in her complaint. Paragraph 9 of the complaint specifically alleges that “foreclosure proceedings were initiated in September of 2007 and recorded in the office of the prothonotary under civil action 11365-2007.” Additionally, paragraphs 10 through 14 reference procedures that occurred in that action including an order of court entered therein that resulted in a finding that the mobile home located upon her real estate was in fact part of the real estate and subject to the foreclosure proceedings. Here, the defense of res judicata may be raised by preliminary objection because of plaintiff’s reference to the prior judgment in her complaint.

Additionally, if plaintiff wished to challenge the defendant’s method of raising the res judicata claim by preliminary objection, the proper procedure would have been a preliminary objection in the nature of motion to strike because of lack of conformity to law or rule of court, such procedure being required by Pa.R.C.P. 1017(b)(2). Since plaintiff has failed to avail herself of the appropriate procedure to challenge any alleged improper matter contained in defendant’s preliminary objection and has in fact addressed the defendant’s preliminary objections on their merits, acknowledging not only the foreclosure action, but the proceedings before the magisterial district court, the court will therefore address the merits of the res judicata claim. See Rufo v. The Bastian-Blessing Co., 417 Pa. 107, 207 A.2d 823 (1965); Callery v. Municipal Authority of Blythe Township, supra.

The foreclosure action at Case No. 11365 of2007, C.A. relative to plaintiff’s mortgaged property, and brought on the same mortgage identified in this action, was filed on September 12, 2007. The complaint was served by the [512]*512sheriff of Lawrence County by personal service upon the plaintiff on September 17, 2007. Plaintiff did not file an answer nor otherwise respond to the complaint, nor did she ever retain counsel. A default judgment in rem was entered against the plaintiff on October 31, 2007.

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

Related

Fox v. Gabler
626 A.2d 1141 (Supreme Court of Pennsylvania, 1993)
Chada v. Chada
756 A.2d 39 (Superior Court of Pennsylvania, 2000)
McGill v. Southwark Realty Co.
828 A.2d 430 (Commonwealth Court of Pennsylvania, 2003)
Callery v. Blythe Township Municipal Authority
243 A.2d 385 (Supreme Court of Pennsylvania, 1968)
Stevenson v. Silverman
208 A.2d 786 (Supreme Court of Pennsylvania, 1965)
Fleming v. Strayer
80 A.2d 786 (Supreme Court of Pennsylvania, 1951)
Del Turco v. Peoples Home Savings Ass'n
478 A.2d 456 (Supreme Court of Pennsylvania, 1984)
Rufo v. the Bastian-Blessing Co.
207 A.2d 823 (Supreme Court of Pennsylvania, 1965)
O'Connor v. O'Connor
139 A. 734 (Supreme Court of Pennsylvania, 1927)
Hochman v. Mortgage Finance Corp.
137 A. 252 (Supreme Court of Pennsylvania, 1927)
Jones v. Costlow
47 A.2d 259 (Supreme Court of Pennsylvania, 1946)
Security Trust Co. v. Feist
5 A.2d 119 (Supreme Court of Pennsylvania, 1938)
In re Estate of Banes
388 A.2d 319 (Supreme Court of Pennsylvania, 1978)
Peerless Insurance v. United States
382 U.S. 832 (Supreme Court, 1965)

Cite This Page — Counsel Stack

Bluebook (online)
34 Pa. D. & C.5th 507, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-bank-of-america-pactcompllawren-2013.