Ford Motor Credit Co. v. Roberson

25 A.3d 110, 420 Md. 649, 2011 Md. LEXIS 443
CourtCourt of Appeals of Maryland
DecidedJuly 15, 2011
DocketMisc. No. 15, September Term, 2010
StatusPublished
Cited by17 cases

This text of 25 A.3d 110 (Ford Motor Credit Co. v. Roberson) is published on Counsel Stack Legal Research, covering Court of Appeals of Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ford Motor Credit Co. v. Roberson, 25 A.3d 110, 420 Md. 649, 2011 Md. LEXIS 443 (Md. 2011).

Opinion

*651 BATTAGLIA, J.

We have before us a question of law certified by the United States Bankruptcy Court for the District of Maryland, pursuant to the Maryland Uniform Certification of Questions of Law Act, Maryland Code (1974, 2006 Repl.Vol.), Sections 12-601 et seq. of the Courts and Judicial Proceedings Article and Maryland Rule 8-305, 1 that being:

Whether the repossession of a vehicle based solely on the violation of an ipso facto clause of a vehicle retail installment contract, in the absence of any other breach, is permissible under Maryland law?

In the Certification Order, the bankruptcy judge summarized the circumstances giving rise to the question now before *652 us, involving an action by a debtor, Maureen Roberson, to recover damages because Ford Motor Credit Company had repossessed her car shortly after she was discharged in bankruptcy, even though she had made timely monthly payments on the vehicle indebtedness before, during, and after the bankruptcy proceedings, but failed to “reaffirm” 2 the debt:

The debtor in this case, Maureen Roberson (Ms. Roberson or the “Debtor”) filed a petition under chapter 13 [ 3 ] of title 11 of the United States Code (the “Bankruptcy Code”) on February 21, 2008. According to Ms. Roberson, she filed her petition because Ford Motor Credit Company, LLC (“Ford”) wrongfully repossessed her car in the wake of her prior chapter 7[ 4 ] bankruptcy discharge and she wanted to redress that wrong.
Ms. Roberson filed a previous chapter 7 bankruptcy case (bankruptcy case no. 07-20394) on October 22, 2007 and she received a discharge of her debts on January 30, 2008. On *653 the bankruptcy schedules in her chapter 7 case, she listed Ford as a creditor and the vehicle she financed through Ford (the “Vehicle”) as an asset. She did not reaffirm the Vehicle during her chapter 7 bankruptcy case. There appears to be no dispute that at all times before, during and after Ms. Roberson’s chapter 7 bankruptcy case, she timely made all monthly payments on the Vehicle to Ford and the Vehicle was, at all times, properly insured and titled.

Ms. Roberson had entered into a “Maryland Simple Interest Vehicle Retail Installment Contract,” containing an ipso facto clause, 5 in which, among other contingencies, the filing of a bankruptcy petition was characterized as a default:

To consummate the purchase and finance of the Vehicle, Ms. Roberson and Ford executed a Maryland Simple Interest Vehicle Retail Installment Contract (the “Vehicle Contract”) dated on or about July 11, 2004. The Vehicle Contract contains an ipso facto clause as follows:
F. Default: You will be in default if:
4. You file a bankruptcy petition or one is filed against you.
If you do not cure a default where allowed by law, the Creditor may require you to pay at once the unpaid Amount Financed, the earned and unpaid part of the Finance Charge and all other amounts due under this contract. He may repossess (take back) the vehicle, too. He may also take goods found in the vehicle when repossessed and hold them for you.
Vehicle Contract at page 2.

After Ms. Roberson’s Chapter 7 bankruptcy case was closed, Ford Motor Credit repossessed the car because Ms. Roberson failed to cure the default by executing a reaffirmation agreement. Ms. Roberson, thereafter, filed a Chapter 13 *654 bankruptcy petition, the sole basis for which was to “facilitate recovery” of the car and to seek damages from Ford Motor Credit for “wrongfully, illegally and maliciously” repossessing the car:

On February 19, 2008, about three weeks after Ms. Roberson received her chapter 7 discharge, Ford repossessed Ms. Roberson’s Vehicle on the basis that she had breached the ipso facto clause in the Vehicle Contract by virtue of having filed for bankruptcy protection.
Two days after the repossession of the Vehicle, on February 21, 2008, Ms. Roberson filed the instant chapter 18 case. Ms. Roberson alleges that her sole motivation in filing this case is to redress her rights vis a vis Ford and to attempt to obtain her Vehicle from Ford based on what she asserts was a wrongful taking under Maryland law. Although Ms. Roberson initially filed an Emergency Motion for Return of Vehicle in her main bankruptcy case, she later filed an adversary complaint against Ford.
Ford argues that its repossession of Ms. Roberson’s Vehicle was lawful because Ms. Roberson filed a bankruptcy petition and failed to take steps in her previous chapter 7 case to reaffirm the debt owing to Ford. Accordingly, Ford claims, under Maryland state law and the Vehicle Contract, Ford was permitted to repossess Ms. Roberson’s vehicle based on the ipso facto clause, ie., based on nothing more than the fact that Ms. Roberson filed for bankruptcy protection.
There appears to be no dispute that at all relevant times, Ms. Roberson was current on her payments to Ford, was current on her insurance obligations under the Vehicle Contract and had not breached her contract with Ford in any way, other than having filed a bankruptcy petition. Based on this breach alone, and based on its interpretation of Maryland law, Ford repossessed Ms. Roberson’s car after the dismissal of her first bankruptcy case and before she filed her second bankruptcy case.
Now, in the context of her second bankruptcy case, Ms. Roberson is attempting to redress the allegedly wrongful *655 repossession of her vehicle by Ford. Ford is defending based on its interpretation of Maryland law and the ipso facto clause in the governing contract.

Ms. Roberson alleged that the repossession was in violation of the “Discharge Injunction” 6 in her Chapter 7 case, the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (2006), the Maryland Consumer Protection Act, Sections 13-101 et seq. of the Commercial Law Article, Maryland Code (1975, 2005 Repl.Vol.), the Maryland Consumer Debt Collection Act, Sections 14-201 et seq. of the Commercial Law Article, Maryland Code (1975, 2005 Repl.Vol.), was a breach of contract, and also formed the basis for trespass and conversion actions. She also filed an “Emergency Motion for Return of Vehicle,” as well. Ford Motor Credit returned the car to Ms.

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Bluebook (online)
25 A.3d 110, 420 Md. 649, 2011 Md. LEXIS 443, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ford-motor-credit-co-v-roberson-md-2011.