Consumer Solutions, LLC v. Theodore R. Thompson

CourtLouisiana Court of Appeal
DecidedJuly 22, 2021
Docket2019CA0214
StatusUnknown

This text of Consumer Solutions, LLC v. Theodore R. Thompson (Consumer Solutions, LLC v. Theodore R. Thompson) is published on Counsel Stack Legal Research, covering Louisiana Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Consumer Solutions, LLC v. Theodore R. Thompson, (La. Ct. App. 2021).

Opinion

NOT DESIGNATED FOR PUBLICATION

STATE OF LOUISIANA

COURT OF APPEAL

FIRST CIRCUIT

2019 CA 0214 R

CONSUMER SOLUTIONS, LLC

VERSUS

r THEODORE R. THOMPSON

Judgment Rendered: JUL 2 2 2021 A

APPEALED FROM THE SIXTEENTH JUDICIAL DISTRICT COURT IN AND FOR THE PARISH OF ST. MARY STATE OF LOUISIANA DOCKET NUMBER 124496

HONORABLE GREGORY P. AUCOIN, JUDGE

Jason R. Smith Attorneys for Plaintiff/Appellant, Monroe, Louisiana GMAT Legal Title Trust 2014- 1, U.S. Bank National Association, As Legal Title Trustee

Marc R. Michaud Attorney for Defendant/Appellee New Orleans, Louisiana Lashanda Kemp Knight, Independent Testamentary Executrix of the Succession of Theodore R. Thompson, Jr.

BEFORE: McDONALD, THERIOT, and CHUTZ, JJ. McDONALD, J.

This is a suit on a promissory note, on remand from the Louisiana Supreme

Court. After review, we reverse and render judgment.

FACTS AND PROCEDURAL HISTORY

Consumer Solutions, LLC filed suit against the defendant, Theodore R.

Thompson, maintaining that Mr. Thompson had defaulted on a promissory note

and that it was entitled to enforce the note. Mr. Thompson' s daughter, Lashanda

Kemp Knight, was thereafter substituted as defendant as the independent

testamentary executrix of his succession. GMAT Legal Title Trust 2014- 1, U.S.

Bank National Association, As Legal Title Trustee ( GMAT) was substituted as

plaintiff. The case proceeded to trial. Afterward, the trial court found that GMAT

had failed to establish its right to enforce the note against the succession and

dismissed the suit with prejudice. This court affirmed that judgment. Consumer

Solutions LLC v. Thompson, 2019- 0214 ( La. App. 1 Cir. 9/ 2/ 20), 2020 WL

5229434 ( unpublished).

GMAT filed a supervisory writ with the Louisiana Supreme Court, which

granted the writ. The Louisiana Supreme Court found that GMAT successfully

made a prima facie case of its right to enforce the note. It reversed this court' s

judgment and remanded the case to this court for consideration of the affirmative

defenses raised by Ms. Knight on behalf of the succession. Consumer Solutions,

LLC v. Thompson, 2020- 01359 ( La. 2/ 9/ 21), 309 So. 3d 730 ( per curiam).

THE AFFIRMATIVE DEFENSES

Ms. Knight raised nineteen affirmative defenses: fraud; lack of standing; no

payment supporting equitable lien/ subrogation; unauthentic endorsements; lack of

default; res judicata/ estoppel; quasi -estoppel; failure to comply with federal loan

servicing requirements; failure to perform a condition precedent; HUD violations;

2 illegal charges added to balance; unclean hands; violation of the Fair Debt

Collection Practices Act; violation of the Truth -In -Lending Act; violation of the

Real Estate Settlement and Procedures Act; violation of the Home Ownership

Equity Protection Act; lack of notice of assignment, sale, or transfer of servicing;

abuse of process; and collateral source payments. As GMAT has made a prima

facie case of its right to enforce the note, the burden then shifted to Ms. Knight

to prove any affirmative defenses. See Hancock Bank of Louisiana v. C & O

Enterprises, LLC, 2014- 0542 ( La. App. 1 Cir. 12/ 23/ 14), 168 So. 3d 595, 599,

writ denied, 2015- 0625 ( La. 5/ 22/ 15), 171 So. 3d 251.

The first affirmative defense is fraud. Ms. Knight maintains that GMAT is

not the real party in interest and has not established that it is the holder of the note.

As it has been determined that GMAT has established its right to enforce the note

against the succession, this defense has no merit. See Consumer Solutions, LLC

v. Thompson, 309 So. 3d at 730- 731.

The second affirmative defense is a lack of standing. Ms. Knight maintains

that GMAT is not a real party in interest and lacks standing to move forward with a

foreclosure action. As it has been determined that GMAT has established its right

to enforce the note against the succession, this defense has no merit. See

Consumer Solutions, LLC v. Thompson, 309 So. 3d at 730- 731.

The third affirmative defense is that there is " No Payment Supporting

Equitable Lien/ Subrogation." In this defense Ms. Knight maintains that GMAT

failed to show an ownership interest in the note. As it has been determined that

GMAT has established its right to enforce the note against the succession, this

defense has no merit. See Consumer Solutions, LLC v. Thompson, 309 So. 3d at

730- 731.

The fourth affirmative defense is unauthentic endorsements. Ms. Knight

3 denied the authenticity of every endorsement on the note and mortgage. As noted

earlier, it has been determined that GMAT has established its right to enforce the

note against the succession. See Consumer Solutions, LLC v. Thompson, 309

So. 3d at 730- 731. Further, at the trial, Keywanda Kemp ( Mr. Thompson' s

daughter, and Ms. Knight' s sister) testified that she remembered when Mr.

Thompson bought the house and acquired the mortgage. She testified that she was

present at the closing and was present when he signed all the documents. Thus, the

testimony of Ms. Knight' s witness, Ms. Kemp, established that Mr. Thompson

signed the documents. Ms. Knight failed to prove this affirmative defense.

The fifth affirmative defense is lack of default. Ms. Knight maintains that

GMAT failed to show a default as required by the note. The note provides that:

If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal that has not been paid and all the interest I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means.

GMAT presented the testimony of Roger Martin, custodian of records for

Rushmore Loan Management Services, LLC ( Rushmore), the mortgage servicer.

Mr. Martin testified that he reviewed the file and the documents and reviewed the

information for accuracy. He testified that Rushmore verified the information in

the file. Mr. Martin testified that after the loan went into default, a demand letter

was sent and the loan was accelerated. In the request for admissions sent to Ms.

Knight, request for admission number one asked Ms. Knight to admit or deny that

the demand letter dated January 20, 2012, attached as Exhibit A was received. Ms.

Knight answered that the demand letter attached as Exhibit A was addressed to Ms.

Knight' s father, who was now deceased, and that Ms. Knight had no way of

knowing whether it was sent or received. Thus, while Ms. Knight maintained in

this affirmative defense that no notice of demand was given, she admitted in her 4 response to the requests for admission that the notice of demand was addressed to

her father, and thus she had no way of knowing whether it was sent or received.'

Ms. Knight failed to prove this affirmative defense.

The sixth affirmative defense is res judicata/estoppel. Ms. Knight maintains

that the note is non-negotiable paper and that GMAT does not have the rights of a

holder in due course. As it has been determined that GMAT has established its

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

Related

Hancock Bank of Louisiana v. C & O Enterprises, LLC
168 So. 3d 595 (Louisiana Court of Appeal, 2014)
Hancock Bank of Louisiana v. C & O Enterprises, LLC
171 So. 3d 251 (Supreme Court of Louisiana, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Consumer Solutions, LLC v. Theodore R. Thompson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/consumer-solutions-llc-v-theodore-r-thompson-lactapp-2021.