LPP Mortgage Ltd. v. Underwood Towers Ltd. Partnership

Supreme Court of Connecticut·Decided August 11, 2026·No. SC21237·Published

Opinion

************************************************ The “officially released” date that appears near the beginning of an opinion is the date the opinion will be published in the Connecticut Law Journal or the date it is released as a slip opinion. The operative date for the beginning of all time periods for the filing of postopinion motions and petitions for certification is the “officially released” date appearing in the opinion. All opinions are subject to modification and technical correction prior to official publication in the Connecti- cut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports. In the event of discrepancies between the advance release version of an opinion and the version appearing in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports, the latest version is to be considered authoritative. The syllabus and procedural history accompanying an opinion that appear in the Connecticut Law Journal and subsequently in the Connecticut Reports or Connecticut Appellate Reports are copyrighted by the Secretary of the State, State of Connecticut, and may not be reproduced or distributed without the express written permission of the Commission on Official Legal Publications, Judicial Branch, State of Connecticut. ************************************************ LPP Mortgage Ltd. v. Underwood Towers Ltd. Partnership

LPP MORTGAGE LTD. v. UNDERWOOD TOWERS LIMITED PARTNERSHIP ET AL. (SC 21237) Mullins, C. J., and McDonald, D’Auria, Ecker, Dannehy and Bright, Js.

The substitute plaintiff, L Co., sought to foreclose a mortgage on certain commercial property leased by the named defendant, U Co., from the defen- dant city of Hartford. After U Co. defaulted, it executed a second mortgage and promissory note. Following a further default, U Co. executed another note and agreed to certain modifications to the second mortgage. When the second mortgage and both notes were thereafter sold to L Co., L Co. was pro- vided with a lost note affidavit in which the seller averred that the last note had been lost. In L Co.’s action seeking foreclosure and damages, U Co. and the defendant C Co., U Co.’s management agent, filed a motion to dismiss, claiming that L Co. lacked standing to pursue foreclose under the Uniform Commercial Code (UCC) (§§ 42a-3-301 and 42a-3-309) insofar as L Co. did not possess the lost note when it was lost. The trial court denied the motion to dismiss, concluding that, pursuant to New England Savings Bank v. Bedford Realty Corp. (238 Conn. 745), L Co. had standing to foreclose the mortgage, so long as there was evidence establishing L Co.’s ownership of the debt underlying the note. The trial court subsequently rendered a judgment of strict foreclosure and awarded damages to L Co. U Co. and C Co. appealed to the Appellate Court, claiming that the trial court had incorrectly determined that L Co. had standing. The Appellate Court concluded that, even though L Co. was not in possession of the lost note when it was lost and, therefore, could not enforce the note under the UCC, it nevertheless had standing to pursue the equitable remedy of foreclosure as the owner of the debt. The Appellate Court thus affirmed the trial court’s judgment and remanded the case for the purpose of setting new law days. On remand, the trial court opened its previous judgment of strict foreclosure for the purposes of setting new law days and to consider L Co.’s motion for attorney’s fees, and U Co. and C Co. filed new motions to dismiss, again asserting that L Co. lacked standing to foreclose the mortgage. They claimed that they were entitled to relitigate the issue of standing because, after the disposition of their appeal before the Appellate Court, this court overruled Bedford Realty Corp. sub silentio in Bank of New York Mellon v. Tope (345 Conn. 662) and changed the law of standing by holding that a plaintiff’s standing to foreclose a mortgage is dependent on its right to enforce the promissory note under the UCC at the time it commenced the foreclosure action. In denying these new motions to dismiss, the trial court concluded that the law governing standing under these circumstances had not changed and rejected U Co. and C Co.’s claim concerning L Co.’s standing based on, inter alia, the doctrine of res judicata. The trial court then rendered a judgment of strict foreclosure, from which U Co. and C Co. appealed, contending that the trial court had improperly denied their motions to dismiss. Held: LPP Mortgage Ltd. v. Underwood Towers Ltd. Partnership

This court concluded that the trial court had properly denied U Co.’s and C Co.’s motions to dismiss, as the doctrine of res judicata barred them from relitigating their claim regarding L Co.’s standing to pursue foreclosure.

U Co. and C Co. previously had the opportunity to litigate their claim that L Co. lacked standing to pursue foreclosure on the ground that it could not enforce the lost note under the UCC, that claim was squarely before the Appellate Court in their prior appeal, and that court expressly considered and rejected that claim.

Moreover, this court rejected U Co. and C Co.’s contention that they were nevertheless entitled to review of their standing claim by the trial court on remand on the ground that this court, in Tope, had changed the law govern- ing that claim after the Appellate Court decided U Co. and C Co.’s appeal in L Co.’s favor.

Specifically, this court rejected U Co. and C Co.’s contention that Tope had overruled Bedford Realty Corp. sub silentio, as the underlying facts in Tope did not implicate the principles set forth in Bedford Realty Corp., and there was nothing in this court’s decision in Tope that was inconsistent with its decision in Bedford Realty Corp. or that otherwise indicated that Bedford Realty Corp. was no longer controlling precedent.

Furthermore, this court rejected U Co. and C Co.’s contention that the doctrine of res judicata was inapplicable because there was no longer an existing final judgment after the trial court, on remand, opened the judg- ment of strict foreclosure.

The trial court opened the judgment of strict foreclosure for the limited purposes of setting new law days and considering an award of attorney’s fees, the judgment thus was not opened in its entirety, and, accordingly, that judgment remained final in the res judicata sense as to the issue of L Co.’s standing to pursue foreclosure.

Argued May 13—officially released August 11, 2026

Procedural History

Action to foreclose a mortgage on certain real prop- erty owned by the defendant city of Hartford in which the named defendant held a leasehold interest, and for other relief, brought to the Superior Court in the judi- cial district of Hartford and transferred to the Complex Litigation Docket; thereafter, LPP Mortgage, Inc., was substituted as the plaintiff; subsequently, the court, Schuman, J., denied the motion to dismiss filed by the named defendant et al.; thereafter, the case was tried to the court, Schuman, J.; judgment of strict foreclosure, from which the named defendant et al. appealed to the LPP Mortgage Ltd. v. Underwood Towers Ltd. Partnership

Appellate Court, Cradle, Alexander and Lavine, Js., which affirmed the trial court’s judgment and remanded the case for the purpose of setting new law days; subse- quently, on remand, the court, Farley, J., granted the substitute plaintiff’s motion to open and denied the named defendant’s motion to cure the defaults under- lying the judgment of foreclosure and to reinstate the mortgage; thereafter, the court, Farley, J., denied the motions to dismiss filed by the named defendant et al. and granted the substitute plaintiff’s motion for attor- ney’s fees; subsequently, the court, Farley, J., rendered judgment of strict foreclosure, from which the named defendant et al. appealed.

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