Jimmy R. Nelson v. Hamilton State Bank

CourtCourt of Appeals of Georgia
DecidedMarch 20, 2015
DocketA14A1921
StatusPublished

This text of Jimmy R. Nelson v. Hamilton State Bank (Jimmy R. Nelson v. Hamilton State Bank) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jimmy R. Nelson v. Hamilton State Bank, (Ga. Ct. App. 2015).

Opinion

THIRD DIVISION BARNES, P. J., BOGGS and BRANCH, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. http://www.gaappeals.us/rules/

March 20, 2015

In the Court of Appeals of Georgia A14A1921. NELSON v. HAMILTON STATE BANK.

BRANCH, Judge.

Jimmy R. Nelson signed a commercial promissory note in favor of Bartow

County Bank (BCB) in the original principal amount of $2,977,019.70. Upon

Nelson’s default, Hamilton State Bank (HSB), the successor-in-interest to BCB,

brought suit on the note. The trial court granted summary judgment to HSB for

$2,866,990.37 plus post-judgment interest. On appeal, Nelson contests the amount

of the indebtedness and asserts that there is a genuine issue of material fact as to

whether HSB’s actions directed at his business partner and cousin Dolph Nelson

(“Dolph”) impaired Nelson’s ability to make payments to HSB. For the reasons that

follow, we affirm the judgment of liability and reverse as to damages. Summary judgment is proper when there is no genuine issue of material fact

and the movant is entitled to judgment as a matter of law. OCGA § 9-11-56 (c). We

review a grant or denial of summary judgment de novo and construe the evidence in

the light most favorable to the nonmovant. Home Builders Assoc. of Savannah v.

Chatham County, 276 Ga. 243, 245 (1) (577 SE2d 564) (2003).

So construed, the record shows that Nelson and Dolph are each fifty percent

owners of one or more corporate entities related to the family furniture business; that

in 2005, two of the corporate entities entered into a $3.9 million loan with BCB with

the final payment due on February 21, 2010 (the “furniture business loan”); and that

Nelson was on the board of directors of BCB during that entire time.

Meanwhile in March 2007, Dolph purchased a residence and obtained a

purchase money loan for $586,729.50 from BCB. The associated security deed

included a “dragnet clause,” which provided that the real estate secured the residential

loan and “any and all other and further indebtedness now owing or which may

hereafter be owing, however incurred, to [BCB], its successors and assigns, by

[Dolph Nelson] and [his] successors in title.”1 In November 2007, Dolph obtained an

1 On the day the security deed was recorded, Dolph conveyed his interest in the residence to his wife.

2 equity line of credit (ELOC) on the residence and used the proceeds to pay off the

purchase money note on the residence. Although the purchase money loan was

satisfied as a result, BCB did not cancel the original purchase money security deed

that contained the dragnet clause.

Next, on June 7, 2010, Nelson and Dolph “renewed” the furniture business loan

by each entering into personal loans with BCB: Nelson’s loan, at issue in this case,

was in the amount of $2,977,019.70; and Dolph’s loan was in the amount of

$2,980,336.97. Nelson avers that for several reasons, including certain banking

regulations, BCB required personal loans instead of another commercial loan in the

name of the furniture business entities. Thereafter, the furniture business made 16

monthly payments on each of the personal loans but none after October 2011.

In the meantime, in April 2011, BCB was closed by the Georgia Department

of Banking and Finance; the Federal Deposit Insurance Company was appointed a

receiver, and it assigned Nelson’s promissory note to HSB. In October 2011, Dolph

paid off the equity line of credit and the furniture business made its last payments on

the Nelson and Dolph 2010 promissory notes. Dolph learned several months later that

HSB continued to hold an interest in his personal residence as security for payment

of his 2010 $2.9 million note.

3 In March 2012, HSB brought separate suits against Nelson and Dolph for the

unpaid balance on the two personal notes. The trial court separately granted summary

judgment in favor of HSB in both cases. And Dolph, who is represented by the same

attorneys, has filed a separate appeal.

1. Nelson contends that the trial court erred by rejecting as a matter of law his

defense that his and Dolph’s 2010 promissory notes were inextricably intertwined

such that Nelson should be excused from payment because of HSB’s actions vis-a-vis

Dolph. Nelson asserts that HSB breached its contract with Dolph regarding the

security on his home and improperly “asserted leverage” over Dolph by use of the

dragnet clause, which, Nelson argues, should have been extinguished when Dolph

satisfied his residential purchase mortgage debt in November 2007 with the proceeds

of the ELOC. Nelson also asserts that there are issues of fact as to whether HSB

intended to consider Dolph’s residence as a part of its security for Dolph’s 2010

promissory notes. We agree with HSB that this enumeration of error lacks merit.

First, Nelson has not asserted that he was a party to or a third-party beneficiary

of Dolph’s residential mortgage, the ELOC, or Dolph’s 2010 promissory note.

Accordingly, he lacks standing to raise claims based on those transactions. Dominic

v. Eurocar Classics, 310 Ga. App. 825, 828 (1) (714 SE2d 388) (2011) (“As a general

4 rule, one not in privity of contract with another lacks standing to assert any claims

arising from violations of the contract.”) (citations omitted). See also Jurden v. HSBC

Mtg.Corp., 330 Ga. App. 179 (1) (765 SE2d 440) (2014) (where plaintiff was not a

party to loan agreement or assignment of security interest nor a third party beneficiary

under either agreement, he lacked standing to challenge either agreement) (physical

precedent only); OCGA § 9-2-20.2

Instead, Nelson argues that the two 2010 promissory notes were “inextricably

intertwined” and that therefore he was affected by HSB’s actions vis-a-vis Dolph’s

promissory note. See Iwan Renovations v. North Atlanta Nat. Bank, 296 Ga. App.

125, 128 (1) (673 SE2d 632) (2009) (“As a general rule, two debts that are incurred

for the same purpose, secured by the same property, held by the same creditor, and

owed by the same debtor are inextricably intertwined.”) (citations and footnotes

omitted.) When separate debts are seen as inextricably intertwined, Georgia courts

2 OCGA § 9-2-20 provides as follows: (a) As a general rule, an action on a contract, whether the contract is expressed, implied, by parol, under seal, or of record, shall be brought in the name of the party in whom the legal interest in the contract is vested, and against the party who made it in person or by agent. (b) The beneficiary of a contract made between other parties for his benefit may maintain an action against the promisor on the contract.

5 reviewing confirmation of foreclosure sales will examine the foreclosure of both

debts when determining whether a deficiency judgment is allowed under the

confirmation statute (OCGA § 44-14-161).3 We know of no case law, and Nelson has

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Related

Home Builders Ass'n of Savannah, Inc. v. Chatham County
577 S.E.2d 564 (Supreme Court of Georgia, 2003)
Iwan Renovations, Inc. v. North Atlanta National Bank
673 S.E.2d 632 (Court of Appeals of Georgia, 2009)
Alexander v. Wachovia Bank, National Ass'n
700 S.E.2d 640 (Court of Appeals of Georgia, 2010)
Dominic v. Eurocar Classics
714 S.E.2d 388 (Court of Appeals of Georgia, 2011)
Jurden v. HSBC Mortgage Corp.
765 S.E.2d 440 (Court of Appeals of Georgia, 2014)
Lockwood v. Federal Deposit Insurance Corporation
767 S.E.2d 829 (Court of Appeals of Georgia, 2015)
Hanna v. First Citizens Bank & Trust Co.
744 S.E.2d 894 (Court of Appeals of Georgia, 2013)
Myers v. First Citizens Bank & Trust Co.
750 S.E.2d 378 (Court of Appeals of Georgia, 2013)

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