Farmer v. Federal National Mortgage Ass'n

31 Mass. L. Rptr. 204
CourtMassachusetts Superior Court
DecidedMay 9, 2013
DocketNo. SUCV201203736B
StatusPublished
Cited by3 cases

This text of 31 Mass. L. Rptr. 204 (Farmer v. Federal National Mortgage Ass'n) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Farmer v. Federal National Mortgage Ass'n, 31 Mass. L. Rptr. 204 (Mass. Ct. App. 2013).

Opinion

Fahey, Elizabeth M., J.

Defendant Harmon and Bank Defendants1 (collectively “Defendants”) each move to dismiss plaintiff Dennis Farmer’s amended complaint.2 Farmer moves for partial summary judgment on Count IV: Trespass, Count VI: Action to Quiet or Establish Title to Land, and Count VII: Declaratory Judgment.3 For the reasons stated herein, Defendants’ Motions to Dismiss, in part treated as a Rule 56 Motion,4 are DENIED and Farmer’s Motion for Partial Summary Judgment is ALLOWED IN PART and DENIED IN PART.

Defendants’ Motions to Dismiss require that the issue of resjudicatabe addressed. Farmer’s Motion for Partial Summary Judgment requires that this court [205]*205address, among other issues, the assignments of Farmer’s mortgage as well as Defendants’ required compliance with applicable statutes concerning notice of foreclosure.

I. DEFENDANTS’ MOTIONS TO DISMISS5

A. Res Judicata

Farmer claims that the foreclosure process was improper, that the resulting sale was void, and that his chain of title has been clouded. Defendants argue that the principles of res judicata prevent Farmer from now asserting these claims.6 After consideration, this court concludes that Defendants are incorrect.

FNMA, and those in privity with it,7 are judicially estopped from arguing that res judicata bars Farmer’s instant claims. “Judicial estoppel is an equitable doctrine that precludes a party from asserting a position in one legal proceeding that is contrary to a position it had previously asserted in another proceeding.” Otis v. ArbellaMut. Ins. Co., 443 Mass. 634, 639-40 (2005), quoting Blanchette v. School Comm. of Westwood, 427 Mass. 176, 184 (1998). ‘The purpose of the doctrine is to prevent the manipulation of the judicial process by litigants.” Otis, 443 Mass. at 640, quoting Canavan’s Case, 432 Mass. 304, 308 (2000). “Application of the equitable principle of judicial estoppel to a particular case is a matter of discretion.” Id., citing New Hampshire v. Maine, 532 U.S. 742, 750 (2001).

In support of its Motion for Summary Judgment in the Housing Court, FNMA dedicated an entire section of its memorandum to arguing that Farmer was precluded from bringing his counterclaims, including his wrongful foreclosure and G.L.c. 93A counterclaims, in Housing Court.8 Plaintiffs Supp’l Aff. in Supp. of Motion for Summary Judgment, Exhibit B, pp. 7-8. FNMA stressed that because Farmer failed to meet any of the statutory criteria set forth in G.L.c. 239, §8A, Farmer could not avail himself of the right to raise any of his affirmative defenses or counterclaims. Id., Exhibit B, p. 8. While it is true that Farmer was neither a tenant nor a lease-holder under G.L.c. 239, §8a, Bank of New York explicitly authorized the Housing Court to “consider the former homeowner’s defense that the plaintiffs title is invalid because the foreclosure was not conducted strictly according to the statute.” 460 Mass, at 332. FNMA was certainly aware of this proposition as it cited to Bank of New York numerous times throughout its Motion for Summary Judgment filed in the Housing Court. See Farmer’s Supp’l Aff. in Supp. of Motion for Summary Judgment, Exhibit B. However, FNMA never sought to address the merits of Farmer’s counterclaims in the Housing Court, and instead, as noted above, argued that all of Farmer’s counterclaims, including his wrongful foreclosure counterclaims, must fail and should not even be addressed. See id., ExhibitB, pp. 7-8 (“These claims represent insufficient defenses to this action and must fail as a matter of law” and “As a former owner in possession of the property, the Defendant does not meet the statutory criteria for maintaining counterclaims or affirmative defenses in this action”). In turn, the Housing Court’s Memorandum of Decision stated that Farmer “cannot assert an affirmative defense to possession or counterclaims in this summary process action pursuant to G.L.c. 239, §8a, ¶1" and relied on the cases cited by FNMA in its Motion. Id., Exhibit C, p. 4. The Housing Court then dismissed all of Farmer’s counterclaims without prejudice. Id., Exhibit C, p. 5.

FNMA now urges this court to rule that Farmer is barred from asserting his title-related wrongful foreclosure claims on the theoiy that those claims were already litigated in the Housing Court. See Banks’ Supp’l Mem. of Law in Support of Motion to Dismiss, p. 1. FNMA, and those in privity with it, are estopped from asserting that res judicata bars Farmer’s claims after FNMA erroneously argued that the Housing Court could not adjudicate those claims in the first place, and after the Housing Court accepted FNMA’s proposition and dismissed Farmer’s wrongful foreclosure counterclaims without prejudice. See Otis, 443 Mass, at 640-41 (application of judicial estoppel requires both that the position being asserted is directly contrary to the position previously asserted and that the party must have succeeded in convincing the court to accept its prior position). This court will not allow FNMA, and those in privity with it, to manipulate the judicial process in this way and judicially estops FNMA, and those in privity with it, from asserting res judicata.

Notwithstanding these waiver and judicial estoppel bases, this court goes on to address the merits of Defendants’ res judicata argument. It is important to clarify that the term “res judicata? encompasses both claim preclusion and issue preclusion. Kobrin v. Board of Registration in Medicine, 444 Mass. 837, 843 (2005), citing Heacock v. Heacock, 402 Mass. 21, 23, n.2 (1988). The defendant, Harmon, does not distinguish between claim preclusion and issue preclusion and only cites to the broad principles of res judicata. Although Bank Defendants assert that they can establish each element of both issue and claim preclusion, the only principle applicable here is issue preclusion, and therefore, this court need not consider Bank Defendants’ claim preclusion argument.9

“The doctrine of issue preclusion prevents relitigation of an issue determined in an earlier action where the same issue arises in a later action, based on a different claim, between the same parties or their privies.” Heacock, 402 Mass. at 23, n.2. Before precluding a parly from relitigating an issue, a court must determine that (1) there was a final judgment on the merits in the prior adjudication; (2) the issue in the prior adjudication was identical to the issue in the current adjudication; and (3) the party against whom preclusion is asserted was a party (or in privity with a party) to the prior.adjudication. Kobrin, 444 Mass, at 843. “Additionally, the issue decided in the prior ad[206]*206judication must have been essential to the earlier judgment.” Id. at 844, quoting Taper v. North Adams Ambulance Serv., Inc., 428 Mass. 132, 134-35 (1998). “Once the initial criteria for the application of the doctrine of collateral estoppel are satisfied, the court must consider whether such application would be fair in a particular case.” In Re Brauer, 452 Mass. 56, 70 (2008). As the parly moving for dismissal on

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Bluebook (online)
31 Mass. L. Rptr. 204, Counsel Stack Legal Research, https://law.counselstack.com/opinion/farmer-v-federal-national-mortgage-assn-masssuperct-2013.