Green Tree Servicing, LLC v. Cope

CourtSuperior Court of Maine
DecidedMarch 18, 2016
DocketCUMre-14-244
StatusUnpublished

This text of Green Tree Servicing, LLC v. Cope (Green Tree Servicing, LLC v. Cope) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Green Tree Servicing, LLC v. Cope, (Me. Super. Ct. 2016).

Opinion

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STATE OF MAINE SUPERIOR COURT CUMBERLAND, ss CIVIL ACTION Docket No. y-4-244

GREEN TREE SERVICING, LLC,

Plaintiff STti.TE Q}RiH)JNl ON PLAINTIFF'S MOTION v. Cumberla ric FdR'RE~NSIDERATION

THELMA COPE, MAR 2 1 2016

Defendant RECEIVED Before the court is plaintiff's motion for reconsideration of the dismissal of its

foreclosure action with prejudice. For the following reasons, the motion is granted.

FACTS

Plaintiff has filed three complaints against defendant involving the same note

and mortgage. Plaintiff filed the first complaint on September 15, 2009. The parties filed

a stipulation of dismissal without prejudice on February 11, 2011 . Plaintiff filed the

second complaint on June 6, 2011. On October 12, 2012, the court granted plaintiff's

motion to dismiss without prejudice. Plaintiff filed the third complaint on May 28, 2014.

The case was removed from the foreclosure diversion program after defendant's

request for a loan modification was denied. By notice dated May 27, 2015, the parties

were notified of a trial date of July 21, 2015. Plaintiff filed a motion to dismiss without

prejudice on July 13, 2015 on the ground that it did not have standing to proceed to

trial. Defendant opposed the motion on July 21, 2015 and requested that the court grant

the motion to dismiss with prejudice or, in the alternative, enter judgment in her favor.

The court requested that plaintiff's counsel file an affidavit outlining its efforts to

address the standing issue. The affidavit showed that efforts to deal with the original

lender had not been fruitful and prospects for future success appeared minimal.

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The court dismissed the case with prejudice on January 4, 2016. Plaintiff filed its

motion for reconsideration on January 19, 2016. Defendant opposed the motion on

January 29, 2016. Plaintiff filed a reply on February 4, 2016.

DISCUSSION

1. Standard of Review

"Motions for reconsideration of an order shall not be filed unless required to

bring to the court's attention an error, omission or new material that could not

previously have been presented." M.R. Civ. P. 7(b)(5). The court treats a motion to

reconsider as a motion to alter or amend the judgment. M.R. Civ. P. 59(e); S. Me. Props.

Co. v. Johnson, 1999 ME 37,

alter or amend the judgment "unless it is reasonably clear that prejudicial error has been

committed or that substantial justice has not been done." Cates v . Farrington, 423 A.2d

539, 541 (Me. 1980). The moving party bears the burden of showing prejudicial error. Id.

2. Motion for Reconsideration

Citing Bank of N.Y. v. Dyer, 2016 ME 10, _ A.3d __J plaintiff argues that the

court lacked the power to dismiss the case with prejudice because plaintiff did not have

standing at the time of the dismissal. (Pl.'s Mot. Recons. 1-3.) In Dyer, the plaintiff filed

a complaint for foreclosure in July 2008. Id.

the plaintiff moved to continue because it could not produce the original note. Id.

The court continued the trial until October 11, 2013. Id. On October 11, 2013, the court

continued the trial until November 20, 2014 because the plaintiff wished to add a party­

in-interest. Id. On September 22, 2014, the plaintiff moved to dismiss without prejudice

because it lacked standing following Bank of Am., N.A. v . Greenleaf, 2014 ME 89, 96

A .3d 700. Id. The court dismissed the action without prejudice. Id.

The Law Court affirmed, holding that:

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Because there is no dispute that the Bank lacked standing ... the trial court's power to make any adjudication on the merits of that claim, including a dismissal with prejudice, was not invoked. Accordingly, a dismissal without prejudice, which disposed of the case without exploring its merits, was the required result.

Id. qr 11.

The Law Court reached the same conclusion in U.S. Bank N.A. v. Curit, 2016 ME

17, qr 10, _ A.3d _. In Curit, the plaintiff filed a complaint for foreclosure in March

2013. Id. qr 5. Although trial was scheduled for August 13, 2014, plaintiff filed a motion

to continue on July 23, 2014, citing a Greenleaf standing issue. Id. Trial was continued

until October 14, 2014. Id. One week before trial, plaintiff filed a motion to dismiss

without prejudice, again citing Greenleaf. Id. The court initially dismissed the action

with prejudice, but later changed the dismissal to a dismissal without prejudice. Id. qrqr

6-8. Although the Law Court vacated both dismissals on procedural grounds, it held

that dismissal without prejudice was the proper result:

The trial court did not have the discretion to dismiss the action with prejudice because the bank had not received an assignment from the original lender, and a court may not rule on the merits of a claim if the plaintiff does not have standing to bring the complaint.

Id. qrqr 3, 10.

One possible distinction between Dyer and Curit and this case is that, in this

case, the court intended the dismissal with prejudice to serve as a sanction, whereas in

Dyer and Curit, the court dismissed the actions simply because the plaintiff could not

establish standing at the time of trial. See Dyer, 2016 ME 10, qrqr 4-5, _ A.3d _

(dismissing without prejudice after plaintiff's admission that it could not establish

standing prior to trial); Curit, 2016 ME 17, qr 6, _ A.3d _ (dismissing with prejudice

based on belief that plaintiff could re-file if standing issue was resolved).

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In Dyer, however, the defendant argued that the dismissal without prejudice

granted the plaintiff "a million d ollar mulligan when its inability to perfect a

foreclosure is the result of its own substantive and evidentiary shortcomings." Dyer,

2016 ME 10, en 6, _ A.3d _ . Despite this argument, the Law Court held that dismissal

without prejudice was the "required result" because there was no dispute that the

plaintiff lacked standing. Id. en 11. This was true even though plaintiff had three

attempts at trial and, by the time of trial, more than six years had elapsed since plaintiff

filed the complaint.

Dyer and Curit, therefore, leave the court with little discretion to dismiss

foreclosure actions with prejudice when the plaintiff lacks standing, even when the

plaintiff has engaged in dilatory conduct that warrants a sanction. See JPMorgan Chase

Bank, N .A. v . Ibourk, 2016 Me. Super. LEXIS 31, at *4 (Feb. 16, 2016) ("Because plaintiff

lacked standing at the time the court dismissed its action with prejudice, the court is

compelled to enter a judgment of dismissal without prejudice in place of the dismissal

with prejudice.").

Defendant's argument that the action should be dismissed with prejudice as to

the note and without prejudice as to the mortgage is unpersuasive. (Def.'s Opp'n Mot.

Recons. <[CJ[ 7-8.) Defendant claims that plaintiff has standing as to the note because

there is no dispute that it is the holder of the note. (Id.

the plaintiff must establish standing as to both the note and the mortgage. Greenleaf,

2014 ME 89, en 9, 96 A.3d 700. The court cannot bifurcate the standing analysis by

dismissing the action with prejudice as to only the note. See id. ("Because foreclosure

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Related

SOUTHERN MAINE PROPERTIES CO. v. Johnson
1999 ME 37 (Supreme Judicial Court of Maine, 1999)
Cates v. Farrington
423 A.2d 539 (Supreme Judicial Court of Maine, 1980)
Sturtevant v. Town of Winthrop
1999 ME 84 (Supreme Judicial Court of Maine, 1999)
Mortgage Electronic Registration Systems, Inc. v. Saunders
2010 ME 79 (Supreme Judicial Court of Maine, 2010)
Bank of American, N.A. v. Scott A. Greenleaf
2014 ME 89 (Supreme Judicial Court of Maine, 2014)
Wells Fargo Bank, N.A. v. Jeffrey White
2015 ME 145 (Supreme Judicial Court of Maine, 2015)
The Bank of New York v. John B. Dyer
2016 ME 10 (Supreme Judicial Court of Maine, 2016)
U.S. Bank National Association v. Christopher J. Curit
2016 ME 17 (Supreme Judicial Court of Maine, 2016)

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