McDonough v. First American Title

2011 DNH 015
CourtDistrict Court, D. New Hampshire
DecidedJanuary 28, 2011
Docket10-CV-106-SM
StatusPublished

This text of 2011 DNH 015 (McDonough v. First American Title) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McDonough v. First American Title, 2011 DNH 015 (D.N.H. 2011).

Opinion

McDonough v . First American Title 10-CV-106-SM 1/28/11 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Brian McDonough; Melanie McDonough; and Anne N . Posnack, Tr.; for themselves and on behalf of all others similarly situated, Plaintiffs

v. Case N o . 10-cv-106-SM Opinion N o . 2011 DNH 015 First American Title Insurance Company, Defendant

O R D E R

In a putative class action, removed from the New Hampshire

Superior Court, plaintiffs assert a federal claim under the

Racketeer Influenced and Corrupt Organizations Act (“RICO”)

(Count I ) , as well as state common law claims for breach of

contract and unjust enrichment. Plaintiffs are homeowners who

refinanced mortgages. They allege that First American Title

Insurance Company (“First American”), acting in concert with a

“network” of title agents who sold First American title

insurance, collected premiums at an “original rate,” rather than

a lower “reissue rate” to which they were entitled. Before the

court is defendant’s motion to dismiss the federal RICO claim for

failure to state a claim upon which relief can be granted.

Plaintiffs object. For the reasons given, defendant’s motion to

dismiss is granted. The Legal Standard

A motion to dismiss for “failure to state a claim upon which

relief can be granted,” F E D . R . C I V . P . 12(b)(6), requires the

court to conduct a limited inquiry, focusing not on “whether a

plaintiff will ultimately prevail but whether the claimant is

entitled to offer evidence to support the claims.” Scheuer v .

Rhodes, 416 U . S . 232, 236 (1974). That i s , the complaint “must

contain ‘enough facts to raise a reasonable expectation that

discovery will reveal evidence’ supporting the claims.” Fantini

v . Salem State Coll., 557 F.3d 2 2 , 26 (1st Cir. 2009) (quoting

Bell Atl. Corp. v . Twombly, 550 U . S . 544, 556 (2007)).

When considering a motion to dismiss under Rule 12(b)(6), a

trial court “assume[s] the truth of all well-plead facts and

give[s] the plaintiff[s] the benefit of all reasonable inferences

therefrom.” Vernet v . Serrano-Torres, 566 F.3d 254, 258 (1st

Cir. 2009) (quoting Ruiz v . Bally Total Fitness Holding Corp.,

496 F.3d 1 , 5 (1st Cir. 2007)). “To survive a motion to dismiss,

a complaint must contain sufficient factual matter, accepted as

true, to state a claim to relief that is plausible on its face.”

Sutliffe v . Epping Sch. Dist., 584 F.3d 314, 325 (1st Cir. 2009)

(quoting Ashcroft v . Iqbal, 129 S . C t . 1937, 1949 (2009)).

Finally, however, a Rule 12(b)(6) motion should be granted if

“the facts, evaluated in [a] plaintiff-friendly manner, [do not]

2 contain enough meat to support a reasonable expectation that an

actionable claim may exist.” Andrew Robinson Int’l, Inc. v .

Hartford Fire Ins. Co., 547 F.3d 4 8 , 51 (1st Cir. 2008)

(citations omitted).

Background

The relevant facts, drawn from the complaint and evaluated

in a plaintiff-friendly manner, are as follows.

Brian and Melanie McDonough (“the McDonoughs”), and Anne

Posnack, each refinanced home mortgages in 2008. The refinanced

mortgages were less than five years old. When they refinanced,

the McDonoughs, and Posnack each purchased lender’s title

insurance policies issued by First American. They were charged a

premium applicable to the original issuance of title insurance,

instead of a lower “reissue rate” that applied when “a borrower

refinances within FIVE years of a recorded first mortgage by an

institutional lender.” (Second Am. Decl. (document n o . 2 - 5 ) , at

16.) At all times relevant to this matter, both First American’s

original rate and its reissue rate were on file with the New

Hampshire Insurance Commissioner. Because they paid the original

rate, rather than the lower reissue rate for which they

qualified, the McDonoughs were overcharged by $234.20, and

3 Posnack was overcharged by $364.70. The named plaintiffs claim

to represent many others who are similarly situated.

First American sells title insurance through title agents.

Different title agents handled the transactions described in the

complaint: Monique D. Donovan Law Office, LLC (McDonough), and

Mazerolle & Frasca PA (Posnack). Title agents generally conduct

title searches, that yield information necessary to determine

whether a refinancing homeowner qualifies for First American’s

reissue rate. The title agents are paid commissions by First

American that generally consist of a percentage of the premiums

paid for the policies they sell.

First American’s title agents operate under “title agency

agreements with First American, pursuant to which they arrange,

sell, produce, issue and otherwise assist First American in

issuing title insurance policies.” (Second Am. Decl. ¶ 7 1 ) .

Each “agency agreement . . . states the conditions under which

the title agent is authorized to issue title insurance policies

on behalf of First American.” (Id. at ¶ 76.)

The title agents “are not employees of First American, but

rather they are licensed, nonexclusive agents who work with

different title insurance companies.” (Id. ¶ 72.) They are

4 “separate, independent entities who do not function as

subsidiaries or employees of First American.” (Id.)

“The title agents [conduct title searches and calculate

title-insurance premiums] subject to First American’s direction

and control.” (Id. ¶ 73.) That direction and control

“include[s] the use of standardized systems and procedures for

conducting title searches, for calculating, collecting and

processing payments for title searches and title insurance

policies, and for providing title insurance for lenders and

owners.” (Id. ¶ 75.) First American “has an agent selection

process and audit review program” (id. at ¶ 7 6 ) , “conducts

periodic audits of its title agents” ( i d . ) , and “performs on site

inspections of the title agents’ books and records on an annual

basis” ( i d . ) . First American also “issues the standardized

manuals to be followed by all of the Title Agents in connection

with the production of title insurance policies” (id. ¶ 7 7 ) ; it

“touts . . . [a] title closing production software system

specifically designed by First American for its title agents”

(id. ¶ 7 8 ) ; and it provides its title agents with onsite and

online training for that system ( i d . ) .

In their complaint, and throughout their pleadings,

plaintiffs refer to First American’s “network of title agents.”

5 (Id. ¶ 2.) They allege no facts, however, suggesting any

connection or communication between or among First American’s

title agents. Thus, the phrase “network of title agents” does

not supportably allege any concerted or coordinated activity

between or among those agents.

First American’s title agents also serve as closing or

settlement agents with respect to home purchases. In that role,

they prepare or review the HUD Settlement Statements presented to

homeowners at closing. Those statements list, among other

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