EMC Mortgage Corporation v. Window Box Association, Inc.

CourtCourt of Appeals of Texas
DecidedJuly 9, 2008
Docket10-07-00234-CV
StatusPublished

This text of EMC Mortgage Corporation v. Window Box Association, Inc. (EMC Mortgage Corporation v. Window Box Association, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
EMC Mortgage Corporation v. Window Box Association, Inc., (Tex. Ct. App. 2008).

Opinion

IN THE

TENTH COURT OF APPEALS

 

No. 10-07-00234-CV

EMC Mortgage Corporation,

                                                                                    Appellant

 v.

Window Box Association, Inc.,

                                                                                    Appellee


From the 414th District Court

McLennan County, Texas

Trial Court No. 2006-4201-5

Opinion

            EMC Mortgage Corporation sought to foreclose on certain property owned by Window Box Association, Inc.  Window Box sued EMC seeking a temporary restraining order, a temporary injunction, and a declaratory judgment that EMC’s lien on the property is invalid.  The parties filed competing motions for summary judgment.  Window Box argued that the statute of limitations barred EMC’s right to foreclosure.  The trial court granted Window Box’s motion and dismissed the suit.

On appeal, EMC challenges: (1) the granting of Window Box’s motion for summary judgment and the denial of EMC’s motion (two issues); (2) whether foreclosure is barred by the statute of limitations; (3) Window Box’s standing to assert a statute of limitations defense; (4) the granting of a permanent injunction in Window Box’s favor; and (5) the trial court’s award of attorneys fees to Window Box.  In one cross-point, Window Box challenges the granting of EMC’s motion for leave to amend its counterclaim.  We reverse and remand.

FACTUAL BACKGROUND

            Dolores Vande Veegaete purchased a condominium secured by a note and deed of trust.  Vande Veegaete died in August 2001.  No further payments were made on the note.  The note holder, Liberty Lending Services, sent a notice of default and intent to accelerate in December 2001.  That same month, Window Box filed a notice of lien based on unpaid dues.[1]  In January 2002, Liberty sent a letter to Vande Veegaete’s estate stating that the mortgage was in default and had been placed with an attorney “for the purpose of initiating a foreclosure action.”  Window Box posted a notice of trustee’s sale in May 2002 and foreclosed in June 2002, purchasing the property for $6,059.  Liberty hired a debt collection agency, which sent a notice of representation for collection in August 2002.  At some point, EMC became holder of the note and deed of trust.

In February 2003, EMC filed suit seeking judicial foreclosure, but dismissed its claims without prejudice in November 2005.  In June, August, and November 2006, EMC sent notices to Vande Veegaete’s estate.  EMC posted a notice of trustee’s sale in November 2006.  Window Box subsequently filed suit.

Standing

            In EMC’s fourth issue, it contends that Window Box lacks standing to assert a statute of limitations defense.

Standing is a necessary component of subject matter jurisdiction and involves the court’s power to hear a case.  McAllen Med. Ctr., Inc. v. Cortez, 66 S.W.3d 227, 231 (Tex. 2001); Walston v. Lockhart, 62 S.W.3d 257, 259 (Tex. App.—Waco 2001, pet. denied).  A question of subject matter jurisdiction is fundamental and may be raised at any time.  See In re B.L.D., 113 S.W.3d 340, 350 (Tex. 2003); Walston, 63 S.W.3d at 259.  Subject matter jurisdiction is a question of law subject to de novo review.  See Mayhew v. Town of Sunnyvale, 964 S.W.2d 922, 928 (Tex. 1998).

            EMC asserts that, as junior lienholder, Window Box lacks standing to assert a statute of limitations defense because: (1) its lien is subordinate to EMC’s lien; (2) it has an equitable right to surplus funds; (3) Vande Veegaete’s statute of limitations defense does not run with the land; and (4) its ownership status provides no additional rights because it acquired the property before the maturity date.  Window Box responds that it is no longer merely a junior lienholder, but is the owner of the property and is entitled to rely on the statute of limitations.

To establish standing, an individual must “demonstrate a particularized interest in a conflict distinct from that sustained by the public at large.”  S. Tex. Water Auth. v. Lomas, 223 S.W.3d 304, 307 (Tex. 2007).  “As a general rule, only the mortgagor or a party who is in privity with the mortgagor has standing to contest the validity of a foreclosure sale pursuant to the mortgagor’s deed of trust.”  Goswami v. Metro. Sav. & Loan Asso., 751 S.W.2d 487, 489 (Tex. 1988).  “However, when the third party has a property interest, whether legal or equitable, that will be affected by such a sale, the third party has standing to challenge such a sale to the extent that its rights will be affected by the sale.”  Id.

Window Box possessed an interest in the property that would be affected by a foreclosure sale.  If an affected third party has standing to challenge a foreclosure sale, it follows that the party may also assert any applicable defenses in challenging the sale.  We cannot say that Window Box lacks standing to assert a statute of limitations defense.  We overrule EMC’s fourth issue.

SUMMARY JUDGMENT

            EMC’s first and second issues challenge the granting of Window Box’s motion for summary judgment and the denial of its own motion.

Standard of Review

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