Heller Financial v. Insurance Co. of North America

573 N.E.2d 8, 410 Mass. 400, 1991 Mass. LEXIS 327
CourtMassachusetts Supreme Judicial Court
DecidedJune 13, 1991
StatusPublished
Cited by73 cases

This text of 573 N.E.2d 8 (Heller Financial v. Insurance Co. of North America) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Heller Financial v. Insurance Co. of North America, 573 N.E.2d 8, 410 Mass. 400, 1991 Mass. LEXIS 327 (Mass. 1991).

Opinion

Liacos, C.J.

Insurance Company of North America (INA) appeals from a judgment of the Land Court 2 which subordinated a mortgage held by INA to a mortgage held by Heller Financial (Heller). Heller cross appeals, challenging the judge’s finding that an “estoppel letter” signed by Heller and by Guaranty Bank and Trust Company (GBT) did not constitute a contract. Heller also appeals from the judge’s ruling that neither INA or GBT violated G. L. c. 93A, §§ 2, 11 (1988 ed.). We transferred the appeals to this court on our own motion.

We summarize the facts found by the judge. The story begins with the financial difficulties of New England Roofing Co., Inc., and related companies (NERCO), owned by George Klein and his family. In April, 1981, Klein signed a promissory note to GBT for a principal amount of $720,000, secured by a mortgage on properties owned by N.E.R. Realty Trust, one of the NERCO “related companies.” Klein had signed an earlier note to GBT in December, 1979, which was secured by a mortgage on the same properties. The 1979 mortgage was subordinated to the 1981 mortgage.

After the April, 1981, loan, NERCO continued to experience financial difficulties due to a slowdown in the construction business. As a result, Klein approached Heller requesting a loan that would help NERCO meet its payment obligations to GBT. Heller agreed to loan Klein $550,000 in return for a mortgage on NERCO’s properties. On November 12, 1981, representatives from Heller, NERCO, and GBT met at the latter’s offices, and the following occurred: (1) Heller’s loan to NERCO was closed; (2) GBT discharged the 1979 mortgage which it held on NERCO’s property; (3) GBT and Heller signed an “estoppel letter” which stated, in *402 ter alia, that, of all the debts owed to GET by NERCO, Heller’s mortgage would be subordinated only to the 1981 mortgage. GET and Heller are in disagreement whether the “estoppel letter” was a contract. We shall return to this issue shortly.

NERCO continued to be plagued with financial difficulties. In July, 1982, Heller informed NERCO that, because of nonpayment of its note, Heller was considering accelerating the borrower’s obligations. It was at this time of fiscal crisis for NERCO that INA entered the picture. Most NERCO construction projects were bonded by INA. As of August 3, 1982, NERCO had sixty-one projects under way for a total contract price of $6,347,841. INA had bonded forty-four of the projects for a total of $5,739,030, of which $2,332,023 had been billed and $1,393,030 had been collected. If the bonded jobs were completed, NERCO would receive an additional $4,400,000. If the nonbonded jobs were completed, NERCO would collect $887,000.

INA realized that, if Heller foreclosed on its mortgage, INA would be exposed to large losses. The insurance company, therefore, decided to help NERCO meet its obligations. INA placed money in a trust fund; the money was then transferred to various NERCO accounts and used to satisfy NERCO’s obligations and its debt payments to Heller. Payments were made by using NERCO checks, but the funds belonged to INA. Between August, 1982, and September, 1983, INA (through NERCO) funded payments to Heller totalling $200,000, of which $60,000 was principal. Throughout this time, Heller was unaware that INA was in fact making the payments for NERCO.

On August 31, 1982, INA, GET, and NERCO signed an agreement by which INA agreed to advance funds to complete the bonded projects and was given authority to conduct the financial operation of NERCO. INA also agreed to pay GET $1,700,000 in full satisfaction of the obligations owed it by NERCO. In return, INA was to receive an assignment of all the security held by GET, including the 1981 mortgage. *403 Heller was not informed of the agreement between INA, GBT, and NERCO.

INA could have borrowed the money to pay GBT the $1,700,000. However, since the loan would have affected INA’s reserves, the insurance company decided to have NERCO borrow the money from Consumers Savings Bank (CSB), with the loan to be fully guaranteed by INA. The loan would not have been approved by CSB without INA’s guarantee. At the direction of NERCO, CSB paid the entire amount of the loan to GBT.

In September, 1983, INA (through NERCO) stopped making payments on the Heller loan. In November, 1983, Heller learned for the first time that INA had been funding NERCO. Heller instituted the present action in July, 1984. In May, 1987, Heller and INA agreed to release their respective security interests in the NERCO properties in return for a payment of $900,000 (less certain accrued real estate taxes); the money was deposited in an escrow account. Heller and INA subsequently determined that Heller alone had a mortgage interest in certain real estate parcels. Heller was therefore paid $140,000 from the escrow account. The rest of the money remains in the escrow account awaiting the conclusion of this litigation.

1. Priority of the mortgages. The dispute between INA and Heller centers around whether the assignment of the 1981 mortgage from GBT to INA was valid and, if so, whether it should receive priority over the mortgage held by Heller. Heller argues that the 1981 mortgage was extinguished when GBT was paid $1,700,000 in full satisfaction of NERCO’s obligations to GBT. “[W]hen the money is paid by one whose duty it is by contract, or otherwise, to pay the mortgage, it is a release, though in form it purports to be an assignment.” Carlton v. Jackson, 121 Mass. 592, 596 (1877). See Lydon v. Campbell, 198 Mass. 29, 33 (1908). If the party who pays the mortgagee, however, does not have a legal obligation to pay, we look at the intent of the parties in determining whether the mortgage was extinguished or assigned. Shapiro v. Bailen, 293 Mass. 121, 123 (1936). Brown *404 v. Lapham, 3 Cush. 551, 555 (1849). In determining the intent of the parties, we look at the substance of the transaction, including the relationship between the parties, and not at the form. Ryer v. Gass, 130 Mass. 227, 229 (1881). Brown v. Lapham, supra at 554. We have stated that as a matter of equity, the intent of the parties will not be allowed to control if to do so will be unfair to third parties. Widett & Widett v. Snyder, 392 Mass. 778, 784 (1984).

If NERCO was the party who paid GET, then the mortgage was extinguished, and GBT’s assignment to INA was void. See Carlton v. Jackson, supra. NERCO, however, was practically insolvent at the time of the assignment; it was impossible for NERCO to have paid GBT out of its own funds. Although NERCO signed the note to CSB for the $1,700,000, it was INA’s guarantee which made the loan possible. If we focus on the substance of the transaction, and not on the form, it was INA that borrowed the money from CSB, and it was INA, not the mortgagor NERCO, who paid GBT. Since INA did not have an obligation to pay the debt, the mortgage was not extinguished. Thus, the assignment to INA was valid. See Brown v. Lapham, supra at 555.

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Bluebook (online)
573 N.E.2d 8, 410 Mass. 400, 1991 Mass. LEXIS 327, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heller-financial-v-insurance-co-of-north-america-mass-1991.