Fed'l Home Loan Mortgage v. McCormack

CourtDistrict Court, D. New Hampshire
DecidedAugust 29, 1996
DocketCV-96-81-SD
StatusPublished

This text of Fed'l Home Loan Mortgage v. McCormack (Fed'l Home Loan Mortgage v. McCormack) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fed'l Home Loan Mortgage v. McCormack, (D.N.H. 1996).

Opinion

Fed'l Home Loan Mortgage v. McCormack CV-96-81-SD 08/29/96 UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF NEW HAMPSHIRE

Federal Home Loan Mortgage Corporation, by its servicina agent. Chase Manhattan Mortgage Corporation

v. Civil No. 96-81-SD

Paul McCormack

O R D E R

Chase Manhattan Mortgage Corporation (Chase or CMMC ) , as

servicing agent for the Federal Home Loan Mortgage Corporation,

appeals from the decision of the bankruptcy court (Yacos, J.)

granting debtor Paul B. McCormack's motion for sanctions; finding

that C M M C 's treatment of McCormack's escrow account constituted a

violation of the automatic stay, 11 U.S.C. § 362(a) (6); and

subseguently awarding attorney's fees and punitive damages

pursuant to 11 U.S.C. § 362(h). McCormack additionally moves for

attorney's fees and costs in defending the present appeal.

Background

On June 18, 1986, appellee Paul B. McCormack mortgaged the

sum of $88,000 in order to finance the acguisition of his home in

Hooksett, New Hampshire. Some five years later, on May 17, 1991, appellee filed for bankruptcy under Chapter 13 of the Bankruptcy

Code. The bankruptcy court approved the debtor's plan by

confirming order in March 1992.

CMMC filed a Proof of Claim which included amounts for

certain arrearages; namely, several pre-petition missed mortgage

payments and two post-petition missed mortgage payments, but did

not include any amounts for attorney's fees. The March 1992

confirming order allowed C M M C 's Proof of Claim in the amount of

$8,500. As an additional provision of the confirming order, CMMC

was allowed $700 in attorney's fees relative to the foreclosure

proceedings initiated as a result of appellee's delinguency in

making mortgage payments in late 1990 to early 1991. These

amounts were to be paid pro rata over the term of the Chapter 13

plan by the Trustee.

Discussion

1. The Appeal

A district court's review of bankruptcy court proceedings is

de novo as to rulings of law, but all factual findings will be

accepted unless clearly erroneous. See Jeffrey v. Desmond, 70

F.3d 183, 185 (1st Cir. 1995) (citing In re SPM Mfg. Corp., 984

F .2d 1305, 1311 (1st Cir. 1993); In re GSF Corp., 938 F.2d 1467,

2 1474 (1st Cir. 1991)); Bankr. Rule 8013.1

Appellant's arguments on appeal cast a wide net, but the nub

of the argument can be summarized as follows: whether the

bankruptcy court erred as a matter of law in ruling that certain

of C M M C 's activities constituted a willful violation of the

automatic stay and whether the bankruptcy court erred in ruling

that such willful violation served as a sufficient predicate to

award attorney's fees to the debtor and assess punitive damages

against CMMC.

The bankruptcy court found as follows:

Notwithstanding the plan and the confirming order, and not withstanding the provisions of the Bankruptcy Code that give a debtor in Chapter 13 the power to cure pre-petition defaults. Chase for its own reasons continued to account this loan on the basis that the pre-petition default obligations were still matters that would show up as a negative amount in the escrow account. It was this decision by Chase in my estimation that

1This rule states.

On an appeal the district court or bankruptcy appellate panel may affirm, modify, or reverse a bankruptcy judge's judgment, order, or decree or remand with instructions for further proceedings. Findings of fact, whether based on oral or documentary evidence, shall not be set aside unless clearly erroneous, and due regard shall be given to the opportunity of the bankruptcy court to judge the credibility of the witnesses.

Bankr. Rule 8013 (Supp. 1996).

3 caused this entire course of action and dispute and controversy and numerous phone calls and letters back and forth, et cetera, that stemmed in the hearing before this court to eliminate the confusion created by Chase's decision to simply not comply with the requirements of the Bankruptcy Code and the confirming order in this case. In other words. Chase, notwithstanding the fact that the Bankruptcy Code cures the pre­ confirmation defaults immediately upon the entry of the confirming order, elected to treat that as some kind of contingent thing that it would honor only when and if the Trustee actually made the payments to it. That is not the way any reorganization works under the Bankruptcy Code, whether it be Chapter 11 or Chapter 13 or Chapter 12. The important thing to know about bankruptcy law is that the defaults are cured ipso facto by the entry of the confirming order where they are provided for under the plan with payments to the Trustee to pay them out over time.

December 19, 1995, Transcript of Oral Argument before Judge Yacos

at 112-13. In consequence thereof. Judge Yacos ruled

that Chase did violate the automatic stay by its accounting treatment with regard to this debtor and with regard to this loan by not bifurcating or separating out its accounting to take into account those items that are attributable pre-confirmation to the cure, which would require an account showing what the Trustee was doing or not doing from payments being made by the debtor and showing separately the status of the escrow account and the payment account as a regular monthly payment account, starting afresh from the point of confirmation so that the debtor was not bombarded by statements showing negative balances that required an inordinate amount of time by any borrower, let alone this Court, to thrash out and find out what was actually done.

Id. at 114.

4 The automatic stay provisions of the Bankruptcy Code, 11

U.S.C. § 362(a),2 "were made part of the Code by the Bankruptcy

Reform Act of 1978, to effect a temporary halt to all debt

collection or enforcement proceedings until a court could

reasonably assess the debtor's circumstances and make appropriate

dispositive orders . . . ." Zeoli v. RIHT Mortgage Corp., 148

B.R. 698, 699 (D.N.H. 1993); accord Fish Market Nominee Corp. v.

Pelofsky, 72 F.3d 4, 6 (1st Cir. 1995) ("Section 362(a) protects

the estate of the debtor from adverse claims unless the court

lifts the stay in particular instances, see 11 U.S.C. § 362(d),

2Such portions of said statute here relevant include:

[A] petition filed under section 301, 302, or 303 of this title . . . operates as a stay, applicable to all entities, of-- (1) the commencement or continuation, including the issuance or employment of process, of a judicial, administrative, or other action or proceeding against the debtor that was or could have been commenced before the commencement of the case under this title, or to recover a claim against the debtor that arose before the commencement of the case under this title;

(6) any act to collect, assess, or recover a claim against the debtor that arose before the commencement of the case under this title . . . .

11 U.S.C.

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