Fed. Natl. Mtge. Assn. v. McFerren

2018 Ohio 5319
CourtOhio Court of Appeals
DecidedDecember 31, 2018
Docket28814
StatusPublished
Cited by3 cases

This text of 2018 Ohio 5319 (Fed. Natl. Mtge. Assn. v. McFerren) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fed. Natl. Mtge. Assn. v. McFerren, 2018 Ohio 5319 (Ohio Ct. App. 2018).

Opinion

[Cite as Fed. Natl. Mtge. Assn. v. McFerren, 2018-Ohio-5319.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

FEDERAL NATIONAL MORTGAGE C.A. No. 28814 ASSOCIATION

Appellee APPEAL FROM JUDGMENT v. ENTERED IN THE COURT OF COMMON PLEAS GARRICK P. MCFERREN, et al. COUNTY OF SUMMIT, OHIO CASE No. CV 2015 07 3622 Appellant

DECISION AND JOURNAL ENTRY

Dated: December 31, 2018

CALLAHAN, Judge.

{¶1} Appellant, Garrick McFerren, appeals from the judgment of the Summit County

Common Pleas Court in favor of Appellee, Federal National Mortgage Association (“Fannie

Mae”). For the reasons set forth below, this Court reverses and remands.

I.

{¶2} Fannie Mae filed a complaint to foreclose on Mr. McFerren’s residential

mortgage and to obtain a personal judgment against him on the note relative to the property

located at 3209 Deborah Court in Uniontown.1 None of the defendants filed an answer. Fannie

Mae moved for and was granted default judgment and a decree of foreclosure. A week later, Mr.

1 This is the second foreclosure action filed against Mr. McFerren as to this note and mortgage. See BAC Home Loans Servicing, LP v. McFerren, 9th Dist. Summit No. 26384, 2013-Ohio- 3228, ¶ 2-3. (“McFerren I”). The previous foreclosure action involved a different financial entity. Id. In the appeal of that foreclosure action, this Court reversed the trial court’s grant of summary judgment because the record did not demonstrate that the bank had standing to initiate the foreclosure action. Id. at ¶ 5. 2

McFerren filed a motion to vacate the default judgment and leave to file an answer instanter,

both of which were granted. Mr. McFerren’s answer contained various affirmative defenses,

including, but not limited to, lack of standing, failure to satisfy conditions precedent, and

payment of the note.

{¶3} After unsuccessful mediation attempts, Fannie Mae moved for summary judgment

on the complaint. Mr. McFerren filed two identical response briefs, 3 days apart and each by

different counsel. Both of Mr. McFerren’s response briefs included an affidavit by him that was

not executed or notarized. Mr. McFerren opposed the summary judgment motion by arguing that

Fannie Mae lacked standing to bring the foreclosure action, the affidavit submitted by Fannie

Mae was insufficient to establish standing, and Fannie Mae failed to establish damages. Fannie

Mae filed a reply brief.

{¶4} Upon review of the briefs and the evidence, the trial court reserved ruling on the

motion for summary judgment and ordered Fannie Mae to file a supplemental affidavit

establishing that it had standing. In accordance with the trial court’s order, Fannie Mae filed a

supplemental affidavit with attachments regarding the issue of standing. Despite being granted

leave, Mr. McFerren did not file a supplemental response brief or any evidence opposing Fannie

Mae’s additional evidence. After consideration of Fannie Mae’s additional evidence, the trial

court granted Fannie Mae’s motion for summary judgment.

{¶5} Mr. McFerren timely appeals from this judgment entry, asserting three

assignments of error. Of Mr. McFerren’s three assignments of error, the second is dispositive, so

this Court addresses it first. 3

II.

ASSIGNMENT OF ERROR NO. 2

REVIEWING [FANNIE MAE’S] MOTION FOR SUMMARY JUDGMENT DE NOVO, THE RECORD IS CLEAR AND CONVINCING THAT THE TRIAL COURT ERRED TO THE PREJUDICE OF [MR. MCFERREN] BY GRANTING [FANNIE MAE’S] MOTION FOR SUMMARY JUDGMENT IN FAVOR OF [FANNIE MAE].

{¶6} Mr. McFerren argues that the trial court erred in granting summary judgment to

Fannie Mae because it did not establish standing. This Court agrees.

{¶7} Appellate courts consider an appeal from summary judgment under a de novo

standard of review, using the same standard that the trial court applies. See Bonacorsi v.

Wheeling & Lake Erie Ry. Co., 95 Ohio St.3d 314, 2002-Ohio-2220, ¶ 24, citing Doe v. Shaffer,

90 Ohio St.3d 388, 390 (2000). Accordingly, this Court stands in the shoes of the trial court and

conducts an independent review of the record.

{¶8} Summary judgment is proper under Civ.R. 56(C) when: (1) no genuine issue as to

any material fact exists; (2) the party moving for summary judgment is entitled to judgment as a

matter of law; and (3) viewing the evidence most strongly in favor of the nonmoving party,

reasonable minds can only reach one conclusion, and that conclusion is adverse to the

nonmoving party. Civ.R. 56(C); Temple v. Wean United, Inc., 50 Ohio St.2d 317, 327 (1977).

{¶9} Summary judgment consists of a burden-shifting framework. The movant bears

the initial burden of demonstrating the absence of genuine issues of material fact concerning the

essential elements of the nonmoving party’s case. Dresher v. Burt, 75 Ohio St.3d 280, 292-293

(1996). Specifically, the moving party must support the motion by pointing to some evidence in

the record of the type listed in Civ.R. 56(C). Id. Once the moving party satisfies this burden, the

nonmoving party has a “reciprocal burden” to “‘set forth specific facts showing that there is a 4

genuine issue for trial.’” Id. at 293, quoting Civ.R. 56(E). The nonmoving party “‘may not rest

upon the mere allegations or denials of his pleadings,’” but instead must submit evidence as

outlined in Civ.R. 56(C). Id., quoting Civ.R. 56(E).

{¶10} The plaintiff moving for summary judgment in a foreclosure action must present

evidentiary-quality materials showing: (1) the movant is the holder of the note and mortgage, or is a party entitled to enforce the instrument; (2) if the movant is not the original mortgagee, the chain of assignments and transfers; (3) the mortgagor is in default; (4) all conditions precedent have been met; and (5) the amount of principal and interest due.

(Internal quotations and citations omitted in original.) The Bank of New York Mellon v. Bridge,

9th Dist. Summit No. 28461, 2017-Ohio-7686, ¶ 10, quoting Bank of Am., N.A. v. Edwards, 9th

Dist. Lorain Nos. 15CA010848, 15CA010851, 2017-Ohio-4343, ¶ 10.

{¶11} A plaintiff in a foreclosure action must have standing at the time it files the

complaint in order to invoke the jurisdiction of the court over the foreclosure action. See Fed.

Home Loan Mtge. Corp. v. Schwartzwald, 134 Ohio St.3d 13, 2012-Ohio-5017, ¶ 41. See also

Bank of Am. N.A. v. Kuchta, 141 Ohio St.3d 75, 2014-Ohio-4275, paragraph three of the

syllabus, ¶ 22 (standing addresses a court’s “jurisdiction over a particular case, [and] not subject-

matter jurisdiction”). “To prove standing in a foreclosure action, a plaintiff must hold both the

note and the mortgage prior to filing the complaint.” Bank of Am., N.A. v. McCormick, 9th Dist.

Summit No. 26888, 2014-Ohio-1393, ¶ 8. See also Deutsche Bank Natl. Trust Co. v. Holden,

147 Ohio St.3d 85, 2016-Ohio-4603, ¶ 33.

{¶12} As a preliminary matter, Fannie Mae argues that Mr. McFerren’s assignments of

error should be overruled due to his failure to comply with App.R. 16(A)(7) and Loc.R. 7(F).

Fannie Mae contends that Mr. McFerren’s counsel used “recycled, boilerplate assertions” in his

appellant brief and thereby fails to conform to the appellate rules. While this Court will apply 5

the appellate rules as necessary to the deficiencies in Mr. McFerren’s appellate brief, we will do

so in conjunction with our required de novo review of whether Fannie Mae met its initial

Dresher burden in this matter.

{¶13} Mr.

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2018 Ohio 5319, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fed-natl-mtge-assn-v-mcferren-ohioctapp-2018.