Green Rivers Forest, Inc. v. Aetna Life Insurance (In re Green Rivers Forest, Inc.)

200 B.R. 956, 1996 Bankr. LEXIS 1261
CourtUnited States Bankruptcy Court, M.D. Georgia
DecidedOctober 7, 1996
DocketBankruptcy No. 93-53837; Adv. No. 96-5047
StatusPublished
Cited by1 cases

This text of 200 B.R. 956 (Green Rivers Forest, Inc. v. Aetna Life Insurance (In re Green Rivers Forest, Inc.)) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Green Rivers Forest, Inc. v. Aetna Life Insurance (In re Green Rivers Forest, Inc.), 200 B.R. 956, 1996 Bankr. LEXIS 1261 (Ga. 1996).

Opinion

AMENDED MEMORANDUM OPINION

JAMES D. WALKER, Jr., Bankruptcy Judge.

This matter is before the Court on Motion for Summary Judgment by Defendant, Aetna Life Insurance Company (“Aetna”), and Motion for Partial Summary Judgment by Plaintiff, Green Rives Forest, Inc. (“GRF”). In this action, GRF wants the Court to recognize its leasehold rights in two tracts of land which were previously leased to GRF by Aetna’s predecessor in title as part of a leasehold interest totaling 33,000 acres. One tract in dispute contains 887 acres and the other contains 3056 acres. GRF alleges errors in the foreclosure of the two tracts in question. GRF has made no allegations with respect to any of the other leasehold acreage foreclosed by Aetna.

Prior to this adversary proceeding, this Court granted a Motion For Relief From Stay to Aetna in case number 93-53837. That order was entered on October 16, 1995. On February 6, 1996, pursuant to a power of sale contained in a Deed to Secure Debt (“Security Deed”),1 Aetna conducted a foreclosure sale for which it properly advertised all of the acreage which remained subject to the original lease except for the 887-acre tract.2 Aetna was the highest bidder at the sale. The amount and propriety of that bid is not at issue. Subsequent to the sale, Aetna recorded the deed (the “February Deed”) with the Clerk of the Superior Court of Meriwether County (the “Clerk”). The 3056-acre tract in question, although properly advertised as part of the foreclosure sale, was not described in the February Deed. The parties disagree over the reason for that omission. GRF contends that it was an oversight by Aetna, while Aetna claims that the deed contained a description of the 3056-acre tract when recorded, and that an error by the Clerk’s office caused the omission. Citing authority under section 44-2-12 of the Official Code of Georgia Annotated (“O.C.G.A.”),3 Aetna attempted to rerecord the deed so that all property descriptions were included. The Clerk’s office denies any error on their part. GRF contends that the omission of the description of this 3056-acre tract from the deed as recorded results in an abandonment of Aetna’s rights as to those acres omitted from the description.

[958]*958On May 7, 1996, Aetna conducted another foreclosure sale for the 887-acre tract not previously advertised. GRF contends that Aetna had abandoned its interest in those acres and that the second foreclosure is therefore wrongful.

Summary Judgment

Summary judgment is appropriate when there is no dispute as to any material fact and the moving party is entitled to judgment as a matter of law. F.R.Civ.P. 56(c)4; Combs v. King, 764 F.2d 818 (11th Cir.1985). If there is a genuine issue of fact in dispute, summary judgment must be denied. Warrior Tombigbee Transportation Co., Inc. v. M/V Nan Fung, 695 F.2d 1294 (11th Cir.1983). The party seeking summary judgment may do so by showing that an essential element of the non-movant’s case is lacking. Celotex Corp. v. Catrett, 477 U.S. 317, 106 S.Ct. 2548, 91 L.Ed.2d 265 (1986). The non-moving party must then come forward with sufficient proof to establish the existence of an essential element of its claim. If it cannot, summary judgment is appropriate. Id. at 322-323, 106 S.Ct. at 2552-2553.

The 3056-acre tract

The 3056-acre tract of land was described in the advertisement for the February foreclosure sale. For some reason which is unknown at this time, the deed which was recorded by the Clerk, the February Deed, did not contain a description of this property. Aetna contends that an error by the Clerk was the cause of the omission. GRF asserts that Aetna recorded a deed which did not contain a description of the 3056-acre tract.

If this Court is to decide the proper status of this tract of land on motion for summary judgment, there must be no dispute as to any material fact. F.R.Civ.P. 56(c). Here, there is complete disagreement as to the cause of the omission of the description of the 3056-tract from the February Deed. However, as will be shown in the analysis which follows, this fact is not material to the determination of the question. In addition, for the purposes of deciding this issue, there are no other material facts in dispute. Therefore, the Court will now decide the question as a matter of law.

Essentially, Aetna sought to “fix” the February Deed so that it would contain the description of the 3056-acre tract. Aetna contends that the problem was remedied by “rerecording” the deed on March 6, 1996 (the “March Deed”) with the proper description.5 GRF contends that the March Deed does not “fix” the February Deed because the Georgia Code does not permit such a rerecording. Specifically, GRF claims that O.C.G.A. § 44-2-12 entitled “Rerecording lost or destroyed deeds and other instruments; validity,” is the only Georgia Code section permitting a deed to be rerecorded, and that Aetna’s situation does not fall within its provisions. Aetna asserts that the alleged error by the Clerk would allow them to rerecord under this section.

We are faced then, with the question of whether the March Deed had the effect Aet-na intended. The Court holds that the recording of the March Deed properly gives notice of Aetna’s fee simple interest in the 3056-acre tract. However, the authority for such a holding is not founded in O.C.G.A. § 44-2-12. Without reaching the question of whether or not there was error or whether the error was the fault of the Clerk, the Court holds that the March Deed can, at a minimum, be properly characterized as a “corrective deed.”

The customary mode of correcting an error in a deed is for the grantor to execute and deliver to the grantee a corrective deed which is accepted as such by the grantee [footnote omitted].... A corrective deed is valid without any new consideration, and acceptance by the grantee constitutes an admission of the incorrectness of the original deed [footnote omitted].

[959]*959George A. Pindar & Georgine S. Pindar, Georgia Real Estate Law and Procedure § 19-108, at 163 (4th ed.) (1993).

In ail cases where the form of the deed is contrary to the intention of the parties, equity will interfere to make it conform thereto [footnote omitted]. The relief granted does not depend upon how the error originated, [footnote omitted] nor will it be defeated by the negligence of the complaining party if the other party has not been prejudiced [footnote omitted].... The basis of reformation is the proven intention of the parties at the time of delivery of the deed.... Reformation will not be decreed against a purchaser for value without notice....6

Id. § 19-113, at 165.

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200 B.R. 956, 1996 Bankr. LEXIS 1261, Counsel Stack Legal Research, https://law.counselstack.com/opinion/green-rivers-forest-inc-v-aetna-life-insurance-in-re-green-rivers-gamb-1996.