Fannie Mae v. Las Colinas Apartments, LLC

CourtCourt of Appeals of Georgia
DecidedJune 27, 2018
DocketA18A0297
StatusPublished

This text of Fannie Mae v. Las Colinas Apartments, LLC (Fannie Mae v. Las Colinas Apartments, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fannie Mae v. Las Colinas Apartments, LLC, (Ga. Ct. App. 2018).

Opinion

FIRST DIVISION BARNES, P. J., MCMILLIAN and REESE, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules

June 27, 2018

In the Court of Appeals of Georgia A18A0297. FANNIE MAE v. LAS COLINAS APARTMENTS, LLC et al.

REESE, Judge.

Fannie Mae appeals from an order of the Superior Court of Cobb County

denying its motion for summary judgment and granting the cross motion for summary

judgment filed by Las Colinas Apartments, LLC, and Allen Gross (collectively,

“Appellees”) in Fannie Mae’s action seeking a deficiency judgment after

confirmation of a foreclosure sale. For the reasons set forth, infra, we reverse the

order of the trial court and remand the case for proceedings consistent with this

opinion.

Viewed in the light most favorable to Fannie Mae,1 the evidence shows the

following. In April 2008, Las Colinas refinanced a loan with HSBC Realty Credit

1 See Lau’s Corp. v. Haskins, 261 Ga. 491 (405 SE2d 474) (1991). Corporation in the principal amount of $12,500,000, and executed a Multifamily Note

(“Note”) in HSBC’s favor. Gross executed an “Acknowledgment and Agreement of

Key Principal to Personal Liability for Exceptions to Non-Recourse Liability”

(hereinafter, “Guaranty”) that was attached to the Note. The loan was secured by

property commonly known as Las Colinas Apartments (“Property”), located in

Marietta, as set forth and legally described in a “Multifamily Deed to Secure Debt,

Assignment of Rents and Security Agreement” (“Security Deed”). On the same day

the loan was executed, HSBC endorsed the Note and assigned the Security Deed to

Fannie Mae. The Note, Guaranty, and Security Deed are collectively referred to as the

“Loan Documents.”

In 2009 and the first half of 2010, several vendors recorded materialman’s liens

against the Property. In its amended responses to Fannie Mae’s requests for

admission, Las Colinas admitted that it “did not pay or remediate” the liens of

Competitive Services, LLC, Atlanta’s Reliable Roofing Company, Wilmar Industries,

and Newscapes, LLC “within thirty days of [their] creation.”

In addition, Las Colinas failed to make payments as required under the terms

of the Note, and Fannie Mae foreclosed on the Property on October 5, 2010. The

Superior Court of Cobb County confirmed the foreclosure sale, finding, inter alia, that

2 the Property, which had sold to the highest bidder for $5,000,000, brought at least its

fair market value of $3,300,000 at the time of sale.

Fannie Mae filed a complaint for a deficiency judgment against Las Colinas

and Gross, pursuant to the Guaranty he had executed, for the satisfaction of the entire

unpaid indebtedness under the Loan Documents. Fannie Mae alleged that Appellees

were jointly and severally liable on the Note because the recorded materialman’s liens

constituted prohibited “Transfers” of the Property and were therefore “Events of

Default” under the Security Deed.

The trial court granted summary judgment in favor of the Appellees, and

Fannie Mae appealed.

To prevail at summary judgment under OCGA § 9-11-56, the moving party must demonstrate that there is no genuine issue of material fact and that the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law. On appeal from the grant of summary judgment [the appellate court] conducts a de novo review of the evidence to determine whether there is a genuine issue of material fact and whether the undisputed facts, viewed in the light most favorable to the nonmoving party, warrant judgment as a matter of law.2

2 Home Builders Assn. of Savannah v. Chatham County, 276 Ga. 243, 245 (1) (577 SE2d 564) (2003) (citations and punctuation omitted).

3 Further,

the construction of an unambiguous [security] deed, like the construction of any other contract, is a question for determination by the court. The cardinal rule of construction is, of course, to ascertain the intention of the parties, as set out in the language of the contract. In this regard, contract disputes are particularly well suited for adjudication by summary judgment because construction of contracts is ordinarily a matter of law for the court.3

With these guiding principles in mind, we turn now to Fannie Mae’s claims of error.

1. Fannie Mae argues that the trial court erred in finding that its recovery on

the Note was limited to the foreclosure sale proceeds. We agree with Fannie Mae that

the Loan Documents clearly and unambiguously provided for the personal liability

of Appellees on the Note.

It is well established that contract construction entails a three-step process, beginning with the trial court’s determination as to whether the language is clear and unambiguous. If no construction is required because the language is clear, the court then enforces the contract according to its terms. But if there is ambiguity in some respect, the court then proceeds to the second step, which is to apply the rules of contract construction to resolve the ambiguity. Finally, in the third step,

3 Y. C. Dev. Inc. v. Norton, 344 Ga. App. 69, 72-73 (1) (806 SE2d 662) (2017) (punctuation and footnotes omitted; emphasis supplied).

4 if the ambiguity remains after applying the rules of construction, the issue of what the ambiguous language means and what the parties intended must be resolved by a jury. Importantly, as an initial matter, the existence or nonexistence of an ambiguity is a question of law for the court. Should the court determine that ambiguity exists, a jury question does not automatically arise, but rather the court must first attempt to resolve the ambiguity by applying the rules of construction in OCGA § 13-2-2.4

The Note was structured as a non-recourse loan. Specifically, Paragraph 9 (a)

provided in part:

Except as otherwise provided in this Paragraph 9, [Las Colinas] shall have no personal liability under this Note, the Security [Deed] or any other Loan Document for the repayment of the Indebtedness . . . , and [Fannie Mae’s] only recourse for the satisfaction of the Indebtedness . . . shall be [Fannie Mae’s] exercise of its rights and remedies with respect to [the Property].

However, the Note contained exceptions that would result in full personal

liability for Las Colinas under pre-determined circumstances, which included “Events

of Default” by Las Colinas. In relevant part, Paragraph 9 (c) (2) provided that: “[Las

Colinas] shall become personally liable to [Fannie Mae] for the repayment of all of

4 Y. C. Dev. Inc., 344 Ga. App. at 73 (1) (punctuation and footnotes omitted).

5 the Indebtedness[5] upon the occurrence of any of the following Events of Default:

. . . a Transfer that is an Event of Default under Section 21 of the Security [Deed].”

Section 1 (z) of the Security Deed included in its definition of “Transfer” “the

granting, creating or attachment of a lien, encumbrance or security interest (whether

voluntary, involuntary or by operation of law)[.]”

Section 21 (a) (1) of the Security Deed specified that “[t]he occurrence of any

of the following events shall constitute an Event of Default under this Instrument: a

Transfer of all or any part of the Mortgaged Property or any interest in the Mortgaged

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Related

Alliance Partners v. Harris Trust & Savings Bank
467 S.E.2d 531 (Supreme Court of Georgia, 1996)
Lau's Corp., Inc. v. Haskins
405 S.E.2d 474 (Supreme Court of Georgia, 1991)
Home Builders Ass'n of Savannah, Inc. v. Chatham County
577 S.E.2d 564 (Supreme Court of Georgia, 2003)
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806 S.E.2d 662 (Court of Appeals of Georgia, 2017)

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Bluebook (online)
Fannie Mae v. Las Colinas Apartments, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fannie-mae-v-las-colinas-apartments-llc-gactapp-2018.