General Electric Credit Corp. v. Vandever

1 Navajo Rptr. 352
CourtNavajo Nation Supreme Court
DecidedAugust 1, 1978
StatusPublished

This text of 1 Navajo Rptr. 352 (General Electric Credit Corp. v. Vandever) is published on Counsel Stack Legal Research, covering Navajo Nation Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
General Electric Credit Corp. v. Vandever, 1 Navajo Rptr. 352 (navajo 1978).

Opinion

NESWOOD, District Judge

On September 29, 1973, the defendant Mary Tso Vandever purchased a mobile home from Plaza Mobile Homes In Farmington, New Mexico with a downpayment of $2,000,00. The plaintiff was to make one hundred and twenty (120) payments of $153.06. The terms of the installment contract also included property insurance at a charge additional to the purchase price. A copy of the insurance policy that resulted from the contract was never sent to the defendant.

In accordance with the terms of the contract, the entire contract was assigned to the plaintiff, General Electric Credit Corporation (GECC).

The defendant continued to make payments through Oct[353]*353ober, 1976, at which time she decided that she no longer desired to own the mobile home and that she wanted it transfered to a Gladys Antone. The arrangements agreed upon by the defendant and Miss Antone are unclear, except that Miss Antone was to assume the monthly payments.

Beginning in November, 1976, Gladys Antone made payments to GECC which were accepted by the plaintiff. Subsequently, Miss Antone was informed by a representative of GECC that she should apply for a transfer of credit and that there would be no problem in effectuating that transfer of credit.

On April 14, 1977, Miss Antone received a notice from the plaintiff entitled "Statement of Credit Denial, Termination Or Change". Neither of the two boxes under "Description of Adverse Action Taken" were checked. The boxes under "Principal Reason(s) For Adverse Action Concerning Credit" were also unchecked.

Because the notice contained no statement that her credit had been disapproved, and because representatives of GECC had assured her there would be no problem with the transfer of credit, Miss Antone believed there was no problem with the transfer and continued making payments.

In July, 1977, the plaintiff, without stating a reason, refused to accept any further payments from Miss Antone.

[354]*354On October 3, 1977, the plaintiff commenced this action asking for repossession of the mobile home. The summons was not served until December 20, 1977. Answers and counterclaims were filed on February 6, 1978.

During the pendancy of this action, on January 28, 1978, it appears that the plaintiff or its representatives attempted to repossess the mobile home in question. This repossession was prevented by the Navajo Police.

On June 26, 1978, the defendant filed a motion for judgment on the counterclaims alleging that the plaintiff had failed to answer the counterclaims in a timely manner.

A hearing was held on July 18, 1978 in the Crownpoint District Court at which both parties presented evidence and witnesses.

The first matter which must be disposed of by this Court is the Motion for Judgment On the Counterclaims, which is really in the nature of a motion for default judgment. Rule 4 of the Navajo Rules of Civil Procedure requires that an answer to the complaint be filed within thirty (30) days. The rule contains no requirement that an answer be filed to any counterclaims and no requirement that any such answer contain the party's signature.

While it is probably preferrable that answers be filed to counterclaims, this Court cannot enforce such a rule unless It is in [355]*355the Rules of Civil Procedure. Therefore., the Court denied this Motion verbally and will not reach any of the other issues raised surrounding this motion.

It is obvious to the Court that payments on the mobile home were not current as of the date of the filing of this action and no effort has been made to make them so. The last time this account was current appears to be August, 197?. The question which this Court must address is whether the actions of the plaintiff contributed to the causes for the overdue payments. The Court must also ascertain whether repossession is in order.

The actions of GECC in this matter are difficult to understand. The notice denying the transfer of credit is unclear and GECC continued to accept Gladys Antone's payments in spite of the fact that they claimed to have denied the transfer. It seems to this Court that the defendant was entitled to believe for a period of time that the transfer had taken place.

While the defendant may not have taken all necessary steps to ensure that the proper transfer had indeed taken place, the seller must have been aware that Mrs. Vandever was a woman who understood little English and probably would not have understood the requirements of transfer. The fact that GECC was an assignee of the contract does not alter the fact that certain allowances should have been made for this situation. GECC merely stands in place of the seller and is deemed [356]*356to have his full knowledge.

To allow repossession of the mobile home would be to allow GECC to profit from the confusion it created. On the other hand, this Court does not feel the defendant should be allowed to receive something for nothing. At the time she purchased the mobile home, the defendant fully expected to make all the payments. This Court sees no reason that she should not expect to honor that committment now.

Since GECC refused the transfer, this Court will not apply Miss Antone's payments to the amount due. Therefore, the defendant is liable to GECC for the monthly payments due from November, 1976 until the present. As Miss Antone was not a party to this suit, this Court will decline to order GECC to refund her money she paid. If Miss Antone desires a refund, she may sue GECC.

Accordingly, the Court will not order repossession of the mobile home but will require that payments be brought up to date. The backpayments due through July, 1978 total $3,214.26.

The defendant has presented this Court with several counterclaims, three of which can be disposed of immediately.

The first of these counterclaims is that the transaction violated the provisions of 15 U.S.C. 1601 et seep and specifically the regulations thereunder, 12 CFR 226.4 and 12 CFR 226.402.

[357]*3577 NTC 104 mandates that the courts of the Navajo Nation apply federal laws. Therefore, it is apparent that this Court does have jurisdiction over the counterclaims.

However, as the Navajo Court of Appeals stated in Smoak Chevrolet vs. Barton:

"The cause of action... is created solely by federal law and finds no counterpart in any law of the Navajo Nation. Therefore, the Navajo statute of limitations is inapplicable."

Thus, the counterclaim in this action is barred by the one (1) year statue of limitations contained in 15 U.S.C. 1640(e). In those instances where a court has allowed a longer statute of limitations, there was a state law permitting a setoff after the expiration of the federal limit. See Reliable Credit Services vs. Bernard, 339 So.2d 952 (1976, La. App.); Stephens vs. Household Finance Corp., 566 P.2d 1163 (1977, Okla. ) .

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Related

Stephens v. Household Finance Corp.
1977 OK 137 (Supreme Court of Oklahoma, 1977)
Reliable Credit Service, Inc. v. Bernard
339 So. 2d 952 (Louisiana Court of Appeal, 1977)

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Bluebook (online)
1 Navajo Rptr. 352, Counsel Stack Legal Research, https://law.counselstack.com/opinion/general-electric-credit-corp-v-vandever-navajo-1978.