Cary v. Patch Services LLC

CourtDistrict Court, W.D. Washington
DecidedMarch 13, 2024
Docket2:22-cv-00538
StatusUnknown

This text of Cary v. Patch Services LLC (Cary v. Patch Services LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cary v. Patch Services LLC, (W.D. Wash. 2024).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 BEVERLY JANE CARY, 11 Plaintiff, 12 v. CASE NO. 2:22-cv-00538-LK 13 FIRST AMERICAN TITLE INSURANCE COMPANY LENDERS ADVANTAGE, ORDER REGARDING PENDING 14 MOTIONS Defendant. 15 FIRST AMERICAN TITLE INSURANCE 16 COMPANY, 17 Third-Party Plaintiff, v. 18 PATCH SERVICES LLC, 19 Third-Party Defendant. 20

21 This matter comes before the Court on Defendant and Third-Party Plaintiff First American 22 Title Insurance Company’s motion to dismiss Plaintiff Beverly Jane Cary’s third amended 23 complaint, Dkt. No. 27, as well as Third-Party Defendant Patch Services LLC’s motion to dismiss 24 First American’s third-party complaint, Dkt. No. 43. For the reasons set forth below, the Court 1 GRANTS First American’s motion to dismiss, DISMISSES First American’s third-party 2 complaint, and DENIES Patch’s motion to dismiss as moot. 3 I. BACKGROUND 4 A. The July 2019 Patch Agreement and Cary’s Subsequent Bankruptcy Proceedings

5 This dispute arises from an approximately $62,000 payment Cary obtained from Patch in 6 July 2019 to help alleviate her growing debt. Dkt. No. 26 at 5–7, 11–12; see Dkt. No. 26-1 at 61– 7 62. The payment was secured by a lien against Cary’s home. Dkt. No. 26 at 5, 11; Dkt. No. 26-1 8 at 9, 54, 59–60, 69–81. The payment agreement, entitled “PATCH SERVICES LLC REAL 9 ESTATE PURCHASE OPTION AGREEMENT,” granted Patch an option to purchase a 57.91% 10 interest in Cary’s house or, in the event that Cary commenced voluntary bankruptcy proceedings 11 or otherwise “defaulted,” the ability to “declare all sums secured by [the Deed of Trust] 12 immediately due and . . . invoke the power of sale[.]” Dkt. No. 26-1 at 9–11, 45–47, 58, 61, 74. 13 First American acted as the escrow agent in connection with the transaction. Dkt. No. 26 at 3; see 14 also Dkt. No. 26-1 at 69; Dkt. No. 28 at 5–9. Cary alleges that she failed to understand the

15 agreement’s “core terms” at the time of signing, Dkt. No. 26 at 12, and only discovered the nature 16 and consequences of her contract after she filed for voluntary bankruptcy in September 2020 and 17 Patch entered a notice of claim for an amount twice as large as the payment she initially received, 18 id. at 15. See also Dkt. No. 26-1 at 2–7 (Patch’s proof of claim filed in Cary’s bankruptcy 19 proceedings stating a claim for $122,500); In re Beverly Jane Cary, No. 20-12450-TWD (Bankr. 20 W.D. Wash.) (the “2020 action”). 21 On January 18, 2022, while the 2020 action was still ongoing, Cary initiated an adversary 22 proceeding in the bankruptcy court against Patch, Patch Homes, Inc.,1 and First American, 23

24 1 Patch and Patch Homes, Inc. are referred to collectively herein as the “Patch Defendants.” 1 challenging the legality of these entities’ actions in relation to the July 2019 agreement and the 2 terms contained therein. Dkt. No. 1-1 at 1–2; Cary v. Patch Servs. LLC et al., No. 22-01000-TWD 3 (Bankr. W.D. Wash.). A stipulated motion to withdraw the reference was subsequently filed—and 4 granted—in this Court. Dkt. Nos. 1, 9. While litigation continued in this case, Cary reached a

5 settlement with the Patch Defendants in the 2020 action and subsequently dismissed them from 6 this case with prejudice. Dkt. No. 35 at 1. 7 B. Cary’s Allegations Against First American 8 After the Court granted the parties’ stipulated motion for withdrawal of the reference, Cary 9 filed a third amended complaint, again alleging that both the terms of the Patch agreement and the 10 circumstances surrounding its execution were unlawful. See Dkt. No. 26 at 8, 10–14; Dkt. Nos. 9, 11 25–26. Cary’s primary claim against First American is that it included a mandatory arbitration 12 clause in the Escrow General Provisions, which she asserts is “expressly prohibited under federal 13 law in connection with residential mortgage loans” involving “the principal dwelling of the 14 borrower.” Dkt. No. 26 at 3; see also id. at 14 (alleging that First American “act[ed] in collusion

15 with the P[atch] Defendants to further violate TILA [the Truth in Lending Act, 15 U.S.C. § 1601 16 et seq.] which prohibits the use of a mandatory arbitration agreement in connection with a federally 17 regulated mortgage loan” (citing 15 U.S.C. § 1639c(e)(3))); id. at 16 (“[First American] . . . acted 18 in collusion with the other Defendants to facilitate this unlawful loan . . . by insisting that Ms. Cary 19 sign an escrow agreement that includes a mandatory arbitration agreement, in direct contravention 20 of the federal lending laws.”).2 21 Cary formally sets forth two causes of action against First American. Id. at 22–27, 31–33. 22 First, Cary appears to assert a standalone claim for violations of the Washington Escrow Agent 23

2 In light of Cary’s dismissal of the Patch Defendants, the Court discusses only her remaining claims against First 24 American. See Dkt No. 35; Sept. 6, 2022 Minute Order; Dkt. No. 43 at 5. 1 Registration Act, Wash. Rev. Code. § 18.44.011 et seq. (“EARA”), under Section 18.44.301 of the 2 Revised Code of Washington, as well as an EARA claim based on predicate TILA and Washington 3 Consumer Protection Act, Wash. Rev. Code. § 19.86.010 et seq. (“CPA”), violations. Id. at 22– 4 26. Second, Cary avers that by “consummat[ing] an obviously unlawful loan” and including a

5 broad arbitration clause in the escrow provisions, First American engaged in unfair or deceptive 6 business practices in violation of the CPA. Id. at 24–25, 31–32. 7 C. First American’s Motion to Dismiss and Third-Party Complaint Against Patch 8 First American moves to dismiss Cary’s third amended complaint, Dkt. No. 27, and has 9 also filed a third-party complaint against Patch for indemnity, breach of contract, contribution, and 10 declaratory relief following the Patch Defendants’ dismissal from this action, Dkt. No. 38 at 2, 5– 11 8. Prior to filing its complaint, First American sent Patch a letter tendering for defense and 12 indemnity of Cary’s claims, which Patch rejected. Id. at 4–5, 15–16, 18–24. 13 II. DISCUSSION 14 A. Jurisdiction

15 Beyond 28 U.S.C. § 1334(b), see Dkt. No. 9; 28 U.S.C. § 157(d), this Court has subject 16 matter jurisdiction over Cary’s claims against First American pursuant to 28 U.S.C. §§ 1331 and 17 1367, as Cary asserts claims based on violations of TILA, and the Court may exercise supplemental 18 jurisdiction over her non-federal claims. 19 With respect to First American’s claims against Patch, the Court verifies sua sponte 20 whether it may exercise jurisdiction over the third-party complaint. See Arbaugh v. Y&H Corp., 21 546 U.S. 500, 514 (2006) (federal courts “have an independent obligation to determine whether 22 subject-matter jurisdiction exists”); 360 Acct. Sols., LLC v. TaxAssociates, Inc., No. EDCV-21- 23 478-JGB (SHKx), 2022 WL 886146, at *5 (C.D. Cal. Jan. 7, 2022). “[I]t is well settled that

24 supplemental jurisdiction exists over a properly brought third-party complaint.” St. Paul Mercury 1 Ins. Co. v. Del Webb Calif. Corp., No. CV 16-0209 PSG (SPx), 2017 WL 7661491, at *3 (C.D. 2 Cal. Nov. 7, 2017) (quoting Grimes v. Mazda N. Amer.

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