In Re Residential Capital, LLC

CourtCourt of Appeals for the Second Circuit
DecidedFebruary 3, 2026
Docket25-118
StatusUnpublished

This text of In Re Residential Capital, LLC (In Re Residential Capital, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Residential Capital, LLC, (2d Cir. 2026).

Opinion

25-118 (L) In re Residential Capital, LLC

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING TO A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of The United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 3rd day of February, two thousand twenty-six.

PRESENT: REENA RAGGI, SUSAN L. CARNEY, BETH ROBINSON, Circuit Judges. _________________________________________

IN RE: RESIDENTIAL CAPITAL, LLC,

Debtor. _________________________________________

RESCAP LIQUIDATING TRUST, as successor to Residential Funding Company, LLC, ROWENA DRENNEN, individually and as representative of the Kessler Settlement Class, FLORA GASKIN, individually and as representative of the Kessler Settlement Class, ROGER TURNER, CHRISTIE TURNER, individually and as the representatives of Kessler Settlement Class, JOHN PICARD, individually and as the representative of the Kessler Settlement Class, REBECCA PICARD, individually and as the representative of the Kessler Settlement Class, STEVEN MITCHELL, individually and as the representative of the Mitchell Settlement Class, Plaintiffs-Appellants-Cross-Appellees,

RESIDENTIAL CAPITAL, LLC, RUTH MITCHELL, individually and as the representative of the Mitchell Settlement Class,

Plaintiffs,

v. Nos. 25-118 (Lead), 25-131 (CON), 25-138 (CON), 25-225 (XAP)

CERTAIN UNDERWRITERS AT LLOYDS, LONDON, TWIN CITY FIRE INSURANCE COMPANY, CONTINENTAL CASUALTY COMPANY, CLARENDON NATIONAL INSURANCE COMPANY, STEADFAST INSURANCE COMPANY, ST. PAUL MERCURY INSURANCE COMPANY, NORTH AMERICAN SPECIALTY INSURANCE COMPANY,

Defendants-Appellees,

SWISS RE INTERNATIONAL SE,

Defendant-Appellee-Cross-Appellant,

ACE BERMUDA INSURANCE LTD, XL INSURANCE (BERMUDA) LTD., AMERICAN INTERNATIONAL REINSURANCE COMPANY LTD., CHUBB ATLANTIC INDEMNITY LTD.,

Defendants. *

* The Clerk’s office is respectfully directed to amend the caption as reflected above.

2 _________________________________________

FOR PLAINTIFF-APPELLANT-CROSS- VIVEK CHOPRA, Perkins Coie LLP, APPELLEE RESCAP LIQUIDATING TRUST: Washington, D.C., (Selena J. Linde, Perkins Coie LLP, Washington, D.C.; Alexis E. Danneman, Perkins Coie LLP, Phoenix, AZ, on the brief). FOR PLAINTIFFS-APPELLANTS-CROSS R. FREDERICK WALTERS (Karen W. APPELLEES KESSLER AND MITCHELL Renwick, Michael B. Sichter, and J. CLASS MEMBERS: Michael Vaughan, Walters Renwick Richards & Vaughan, P.C., Kansas City, MO; David M. Skeens, Davis Bethune & Jones, LLC, Kansas City, MO, on the brief). FOR DEFENDANTS-APPELLEES TWIN CITY Cara T. Duffield, Lavin Rindner FIRE INSURANCE COMPANY, Duffield LLC, Washington, D.C.; CONTINENTAL CASUALTY COMPANY, Karen Toto, Wiley Rein LLP, CLARENDON NATIONAL INSURANCE Washington, D.C.; Patrick M. Kennell, COMPANY, STEADFAST INSURANCE Kaufman Dolowich LLP, New York, COMPANY, ST. PAUL MERCURY NY; Harry Lee, John O’Connor, INSURANCE COMPANY, NORTH Steptoe LLP, Washington, D.C.; AMERICAN SPECIALTY INSURANCE Ronald P. Schiller, Sharon F. McKee, COMPANY: Hangley Aronchick Segal Pudlin & Schiller, Philadelphia, PA; Patrick Stoltz, Scott A. Schechter, Kaufman Borgeest & Ryan LLP, Valhalla, NY; Kent A. Yalowitz, Daniel R. Bernstein, Arnold & Porter Kaye Scholer LLP, New York, NY. FOR DEFENDANTS-APPELLEES CERTAIN JONATHAN HACKER, O'Melveny & UNDERWRITERS AT LLOYDS, LONDON: Myers LLP, Washington, D.C. (J. Gregory Lahr, DAC Beachcroft LLP, New York, NY, on the brief). FOR DEFENDANT-APPELLEE-CROSS- THORN ROSENTHAL, (Alice Kim, on the APPELLANT SWISS RE INTERNATIONAL brief), Cahill Gordon & Reindel LLP, SE: New York, NY.

Appeal from a judgment of the United States District Court for the Southern

District of New York (Oetken, Judge).

UPON DUE CONSIDERATION WHEREOF, IT IS HEREBY ORDERED,

ADJUDGED, AND DECREED that the district court judgment entered on

December 13, 2024, is AFFIRMED.

Residential Funding Company, LLC (“RFC”) was a financial services

company that purchased mortgage loans from originating banks and then either

packaged and resold or securitized those loans for sale to downstream investors.

RFC did not itself originate mortgages or receive fees related to the mortgage

originations or closings; all fees were paid to the originating banks. RFC, as a

subsidiary of General Motors Corporation, was an insured party under a General

Motors professional liability policy issued by Certain Underwriting Members at

Lloyd’s of London (“Lloyd’s”), as well as under a tower of excess policies written

by other insurers (collectively, with Lloyd’s, “Insurers”). 1 All of the applicable

1 The other insurers are Twin City Fire Insurance Company, Continental Casualty Company, Clarendon National Insurance Company, Steadfast Insurance Company, St. Paul Mercury Insurance Company, North American Specialty Insurance Company, and Swiss RE International

4 policies include terms materially identical to the Lloyd’s policy (the “Policy”) for

purposes of this case.

At issue is whether the Policy covers RFC’s liability relating to two class

actions (the “Mitchell” class action and the “Kessler” class action) alleging primarily

that certain mortgage loan fees charged by the originating banks were unlawful

and that RFC, as purchaser of those loans, was derivatively liable under the Home

Ownership and Equity Protection Act. See 15 U.S.C. § 1641(d)(1). While those

actions were pending, RFC filed for Chapter 11 bankruptcy. The bankruptcy court

ultimately approved a Chapter 11 plan that included settlements of the Mitchell 2

and Kessler actions and assigned to the newly created liquidating Trust and

representatives of both classes (“Class Representatives”) the right to pursue claims

against Insurers for payment of the settlements and related defense costs.

The Trust and Class Representatives (collectively, “Plaintiffs”) then brought

an adversary proceeding to enforce those rights. After cross-motions for partial

summary judgment, the bankruptcy court recommended holding that RFC’s

SE. Four other insurers, ACE Bermuda Insurance Ltd., XL Insurance (Bermuda) Ltd., American International Reinsurance Company Ltd., and Chubb Atlantic Indemnity Ltd., also provided excess coverage but did not participate in the district court proceedings because the bankruptcy court compelled arbitration of the claims against them.

2A portion of the Mitchell class action had previously been resolved by jury verdict. See Mitchell v. Residential Funding Corp., 334 S.W.3d 477, 484 (Mo. Ct. App. 2010), as modified (Feb. 1, 2011).

5 liability and costs were not excluded from coverage by either of two asserted

exclusions. In re Residential Capital, 610 B.R. 725, 737–38, 746–47 (Bankr. S.D.N.Y.

2019). The district court subsequently withdrew its reference to the bankruptcy

court, and it awarded summary judgment to Insurers based on an exclusion in the

Policy for losses arising from any claim “for . . . fees . . .

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Related

Vanguard Insurance v. McKinney
459 N.W.2d 316 (Michigan Court of Appeals, 1990)
Mitchell v. Residential Funding Corp.
334 S.W.3d 477 (Missouri Court of Appeals, 2011)
Jeremy Marchek v. USAA
118 F.4th 830 (Sixth Circuit, 2024)

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Bluebook (online)
In Re Residential Capital, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-residential-capital-llc-ca2-2026.