Kafi, Inc. v. Fairgate Trust

CourtDistrict Court, S.D. Texas
DecidedAugust 15, 2024
Docket4:23-cv-04217
StatusUnknown

This text of Kafi, Inc. v. Fairgate Trust (Kafi, Inc. v. Fairgate Trust) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kafi, Inc. v. Fairgate Trust, (S.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT August 15, 2024 FOR THE SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

§ KAFI, INC., § § Plaintiff, § v. § CIVIL ACTION NO. H-23-4217 § FAIRGATE TRUST, et al., § § Defendants. § § §

MEMORANDUM AND OPINION I. Background In December 2005, Javier Martinez purchased a home in Houston, Texas. He paid for the home, in part, with a promissory note in the principal amount of $29,000, secured by a deed of trust. (Docket Entry No. 24-1). After a decade, Mr. Martinez’s mortgage payments were in arrears. On several dates between 2016 and 2019, Mr. Martinez was sent notices that the deed of trust would be foreclosed and his property would be sold at a “substitute trustee sale.” (Docket Entry Nos. 24-4, 24-5, 24- 6, 24-7). In November 2016, Mr. Martinez was sent a notice of default and intent to accelerate. (Docket Entry No. 24-27). In June 2018, he was sent a notice of acceleration and notice of posting and foreclosure. (Docket Entry No. 24-28). In June 2021, Mr. Martinez entered into a loan modification agreement with the lender. (Docket Entry No. 21-6). In March 2023, Mr. Martinez’s homeowners’ association sued him for unpaid dues. (Docket Entry No. 24-19). The 269th Judicial District Court of Harris County issued an agreed final judgment for foreclosure against Mr. Martinez. (Docket Entry No. 24-20). In October 2023, Kafi, Inc. purchased the home at the foreclosure sale for $36,071. (Docket Entry No. 24-21). Fairgate Trust is the current assignee of the deed of trust. In November 2023, Kafi sued Fairgate, Allied Servicing Corporation, and Mortgage Electronic Registration Systems, Inc. in Texas state court, asserting causes of action for (1) quiet title, (2) a declaration that the defendants

lack standing to foreclose on the property, and (3) a declaration that the statute of limitations has run because a foreclosure sale did not take place under the deed of trust within four years of acceleration. (Docket Entry No. 1-4). The defendants removed to this court on the basis of diversity jurisdiction. (Docket Entry No. 1). In June 2024, the defendants moved for summary judgment. (Docket Entry No. 21). Kafi responded and cross-moved for summary judgment. (Docket Entry No. 24). The defendants replied. (Docket Entry No. 26). Based on the record, the briefs, and the applicable law, summary judgment is granted for Kafi and denied for the defendants. The reasons are set out below.

II. The Rule 56 Standard “Summary judgment is appropriate where ‘the movant shows that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.’” Springboards to Educ., Inc. v. Pharr-San Juan-Alamo Indep. Sch. Dist., 33 F.4th 747, 749 (5th Cir. 2022) (quoting FED. R. CIV. P. 56(a)). “A fact is material if it might affect the outcome of the suit and a factual dispute is genuine if the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Thompson v. Microsoft Corp., 2 F.4th 460, 467 (5th Cir. 2021) (quoting reference omitted). The moving party “always bears the initial responsibility of informing the district court of the basis for its motion[] and identifying” the record evidence “which it believes demonstrate[s] the absence of a genuine issue of material fact.” Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). “When ‘the non-movant bears the burden of proof at trial,’ a party moving for summary judgment ‘may merely point to the absence of evidence and thereby shift to the non-movant the burden of demonstrating by competent summary judgment proof that there is [a dispute] of

material fact warranting trial.’” MDK S.R.L. v. Proplant Inc., 25 F.4th 360, 368 (5th Cir. 2022) (alteration in original) (quoting reference omitted). “However[,] the movant ‘need not negate the elements of the nonmovant’s case.’” Terral River Serv., Inc. v. SCF Marine Inc., 20 F.4th 1015, 1018 (5th Cir. 2021) (quoting Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994) (en banc) (per curiam)). “If ‘reasonable minds could differ’ on ‘the import of the evidence,’ a court must deny the motion.” Sanchez v. Young County, 956 F.3d 785, 791 (5th Cir. 2020) (quoting Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250–51 (1986)). After the movant meets its Rule 56(c) burden, “the non-movant must come forward with ‘specific facts’ showing a genuine factual issue for trial.” Houston v. Tex. Dep’t of Agric., 17 F.4th

576, 581 (5th Cir. 2021) (quoting references omitted). The nonmovant “must identify specific evidence in the record and articulate the ‘precise manner’ in which the evidence” aids their case. Shah v. VHS San Antonio Partners, L.L.C., 985 F.3d 450, 453 (5th Cir. 2021) (quoting reference omitted). Of course, all reasonable inferences are drawn in the nonmovant’s favor. Loftin v. City of Prentiss, 33 F.4th 774, 779 (5th Cir. 2022). But a nonmovant “cannot defeat summary judgment with conclusory allegations, unsubstantiated assertions, or only a scintilla of evidence.” Jones v. Gulf Coast Rest. Grp., Inc., 8 F.4th 363, 369 (5th Cir. 2021) (quoting reference omitted). III. Analysis A secured lender must sue for the foreclosure of a real property lien “not later than four years after the day the cause of action accrues.” Boren v. U.S. Nat’l Bank Ass’n, 807 F.3d 99, 104 (5th Cir. 2015) (quoting TEX. CIV. PRAC. & REM. CODE § 16.035(a)). If the note or deed of trust secured by real property has an optional acceleration clause, the cause of action accrues “when the

holder actually exercises its option to accelerate.” Holy Cross Church of God in Christ v. Wolf, 44 S.W.3d 562, 566 (Tex. 2001). To exercise the option, the note holder must send “both a notice of intent to accelerate and a notice of acceleration.” Boren, 807 F.3d at 104 (citing EMC Mortg. Corp. v Window Box Ass’n, Inc., 264 S.W.3d 331, 335–36 (Tex. App.—Waco 2008, no pet.). “So long as it is preceded by the required notice of intent to accelerate, notice of a trustee’s sale constitutes unequivocal action indicating the debt is accelerated.” Karam v. Brown, 407 S.W.3d 464, 470 (Tex. App.—El Paso 2013, no pet.). The parties do not dispute that Fairgate accelerated the loan a number of times. The parties dispute whether the accelerations were abandoned, by agreement or other party action. If an

acceleration has been abandoned, the limitations period generally restarts. Boren, 807 F.3d at 103– 06; Bitterroot Holdings, L.L.C. v. MTGLQ Inv’rs, L.P., 648 Fed. App’x. 414, 418 (5th Cir. 2016).

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Kafi, Inc. v. Fairgate Trust, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kafi-inc-v-fairgate-trust-txsd-2024.