CIT Bank, N.A. v. Caroline Coffman, as Administratrix of the Estate of Shirley Bowen

CourtIntermediate Court of Appeals of West Virginia
DecidedJune 11, 2024
Docket22-ica-330
StatusPublished

This text of CIT Bank, N.A. v. Caroline Coffman, as Administratrix of the Estate of Shirley Bowen (CIT Bank, N.A. v. Caroline Coffman, as Administratrix of the Estate of Shirley Bowen) is published on Counsel Stack Legal Research, covering Intermediate Court of Appeals of West Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CIT Bank, N.A. v. Caroline Coffman, as Administratrix of the Estate of Shirley Bowen, (W. Va. Ct. App. 2024).

Opinion

IN THE INTERMEDIATE COURT OF APPEALS OF WEST VIRGINIA FILED Spring 2024 Term June 11, 2024 _____________________ released at 3:00 p.m. ASHLEY N. DEEM, DEPUTY CLERK INTERMEDIATE COURT OF APPEALS No. 22-ICA-330 OF WEST VIRGINIA _____________________

CIT BANK, N.A., Plaintiff/Counterclaim Defendant Below, Petitioner,

v.

CAROLINE COFFMAN, as Administratrix of the ESTATE OF SHIRLEY BOWEN, Defendant/Counterclaim Plaintiff Below, Respondent.

___________________________________________________________

Appeal from the Circuit Court of Hampshire County Honorable C. Carter Williams, Judge Civil Action No. CC-14-2016-C-97

AFFIRMED, IN PART, REVERSED, IN PART, VACATED, IN PART, AND REMANDED WITH DIRECTIONS _________________________________________________________

Submitted: April 2, 2024 Filed: June 11, 2024

Marc E. Williams, Esq. Jonathan G. Brill, Esq. Randall L. Saunders, Esq. Jonathan G. Brill, PLLC Shaina D. Massie, Esq. Romney, West Virginia Jonah D. Samples, Esq. Nelson Mullins Riley & Scarborough F. Samuel Byrer, Esq. LLP Law Office of F. Samuel Byrer, PLLC Huntington, West Virginia Charles Town, West Virginia Counsel for Petitioner Counsel for Respondent

JUDGE LORENSEN delivered the Opinion of the Court. LORENSEN, JUDGE:

Petitioner, CIT Bank, N.A. (“CIT”), appeals, in part, the May 6, 2022, order

of the Circuit Court of Hampshire County denying CIT’s motion for a new trial and motion

for judgment as a matter of law. CIT also appeals a November 18, 2022, order granting

punitive damages and a November 22, 2022, order awarding attorney fees. Respondent

Estate of Shirley Bowen (“Ms. Bowen”) asserts a cross-assignment of error regarding the

circuit court’s reduction of punitive damages in the November 18, 2022, order. A jury

found CIT liable for (1) wrongful foreclosure; (2) slander of title; (3) breach of contract;

(4) violations of the West Virginia Consumer Credit Protection Act (“WVCCPA”); (5)

abuse of process; (6) tort of outrage; and (7) fraudulent court record. Ms. Bowen was

awarded $760,000.00 in compensatory damages for her various claims and was

additionally awarded $1,500,000.00 in punitive damages. Following the post-trial motions

presently on appeal, the circuit court reduced Ms. Bowen’s total damages to $1,750,000.00

and separately awarded Ms. Bowen $613,858.35 in attorney fees and costs.

For the reasons below, we affirm the circuit court’s ruling on Ms. Bowen’s

breach of contract and tort of outrage claims. However, we reverse the circuit court’s

holdings on the claims for wrongful foreclosure, slander of title, abuse of process, and

fraudulent court record. We further reverse the circuit court’s order regarding punitive

damages and vacate the order awarding attorney fees. This matter is remanded to the circuit

court for a reconsideration of attorney fees.

1 I. FACTUAL AND PROCEDURAL BACKGROUND

Shirley Bowen purchased her home in Delray, West Virginia, in 1988. Faced

with financial insecurity, she entered into a reverse mortgage arrangement with Financial

Freedom Senior Funding Corporation, now CIT, in 2006. Almost ten years after entering

into the reverse mortgage, Ms. Bowen learned that CIT had foreclosed and sold her home.

She alleged that she received no notice of the foreclosure and was not aware of why CIT

would foreclose.1 Shortly thereafter, CIT filed a Petition to Rescind Foreclosure Sale in the

Circuit Court of Hampshire County, which began the action on appeal.

A reverse mortgage provides regular and reliable income to a homeowner in

exchange for his or her forfeiture of equity in the property. The purpose of a reverse

mortgage is to enable older homeowners to access equity in their homes. See W. Va. Code

§ 47-24-2 (1996). The terms of Ms. Bowen’s reverse mortgage required her to “occupy,

establish, and use the Property as Borrower’s principal residence after execution of this

Security Instrument.” Though she certified her occupancy for the first four years of the

reverse mortgage, Ms. Bowen stopped submitting her written occupancy certifications in

December of 2012.

1 On February 11, 2019, the Estate of Shirley Bowen filed its suggestion of death. Shortly thereafter, Caroline Coffman, Ms. Bowen’s daughter, was substituted for Shirley Bowen as a party to the action, in her capacity as Administratrix of the Estate of Shirley Bowen. 2 On July 2, 2012, Ms. Bowen personally called CIT and requested that her

mailing address be changed from her former Post Office Box (“P.O. Box”) to the property’s

physical address at 1207 Delray Road due to increased P.O. Box fees. On January 7, 2013,

Ms. Bowen completed an occupancy certification form, which listed her daughter, Caroline

Coffman, as her alternative contact. Also on that form was a section that stated, “[i]f this

information is no longer correct, please provide a current alternative contact below.” In this

section, Ms. Bowen left the “Name” space blank but listed the 1207 Delray Road address

in the “Address” space.

On March 29, 2013, Ms. Bowen again submitted a Change of Mailing

Address form, requesting that CIT change Ms. Bowen’s mailing address from her former

P.O. Box to 1207 Delray Road. The form contained a section titled “Reason for Change

(Required)” which Ms. Bowen left blank. CIT received the Change of Mailing Address

form and marked it invalid for its failure to include a reason for the change. Thereafter,

CIT sent Ms. Bowen a letter to the 1207 Delray Road address that stated that CIT had

recently sent mail correspondence to Ms. Bowen that was returned by the postal service

with a forwarding address for Ms. Bowen. The letter stated that CIT could only send notices

to Ms. Bowen at the property address or any other address that Ms. Bowen designates and,

therefore, CIT cannot forward notices to Ms. Bowen to an address which she has not

authorized.2 The letter contained another Change of Mailing Address form that listed the

2 CIT mailed requests to certify occupancy to Ms. Bowen on December 15, 2013, January 3, 2014, and February 15, 2014, all to her former P.O. Box. On May 9, 2014, CIT 3 1207 Delray Road address as the forwarding address provided by the United States Postal

Service. CIT never entered a change of address into its internal system for Ms. Bowen and

as a result, sent all correspondence to Ms. Bowen’s discontinued P.O. Box, as well as to a

physical address for Ms. Bowen’s home listed on the deed of trust.3

On July 29, 2015, CIT sent a “Home Equity Conversion Mortgage

Repayment Notice” to Ms. Bowen’s former P.O. Box. The notice asserted that Ms.

Bowen’s loan had become due and payable because of her alleged failure to occupy the

property. On November 2, 2015, CIT sent Ms. Bowen by regular mail a “Notice of Intent

to Foreclose” to her former P.O. Box. The notice stated that Ms. Bowen’s loan was in

default due to her failure to occupy her home.

On February 18, 2016, CIT foreclosed on Ms. Bowen’s home. CIT then

purchased the property at the sale for $116,000.00 and conveyed title to the property to

Federal National Mortgage Association. Ms. Bowen first became aware of the foreclosure

and conveyance a little less than a month later when she discovered a written notice on her

front door stating that her home had been sold. On March 10, 2016, Ms. Bowen’s daughter,

sent Ms. Bowen a notice of delinquent property taxes for tax year 2013 to her former P.O. Box, which was returned as undeliverable.

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CIT Bank, N.A. v. Caroline Coffman, as Administratrix of the Estate of Shirley Bowen, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cit-bank-na-v-caroline-coffman-as-administratrix-of-the-estate-of-wvactapp-2024.