Melissa Monday-West v. Wells Fargo Bank, N.A.

CourtCourt of Appeals for the Sixth Circuit
DecidedNovember 9, 2022
Docket20-6381
StatusUnpublished

This text of Melissa Monday-West v. Wells Fargo Bank, N.A. (Melissa Monday-West v. Wells Fargo Bank, N.A.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Melissa Monday-West v. Wells Fargo Bank, N.A., (6th Cir. 2022).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 22a0454n.06

Case No. 20-6381

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

FILED Nov 09, 2022 ) MELISSA MONDAY-WEST, as Administratrix DEBORAH S. HUNT, Clerk ) of the Estate of Stanford Lynn West; JAMES D. ) LYON, as Chapter 7 Trustee for the Bankruptcy ) ON APPEAL FROM THE Estate of Melissa Monday-West, ) UNITED STATES DISTRICT Plaintiffs - Appellants, ) COURT FOR THE EASTERN ) DISTRICT OF KENTUCKY v. ) ) OPINION WELLS FARGO BANK, N.A., ) Defendant - Appellee. )

Before: BOGGS, LARSEN, and DAVIS, Circuit Judges.

DAVIS, Circuit Judge.

Melissa Monday-West, as Administratrix of the Estate of Stanford Lynn West, and James

D. Lyon, as Chapter 7 Trustee for the Bankruptcy Estate of Melissa Monday-West (collectively,

the “Wests”), filed this lawsuit against Wells Fargo Bank, N.A. (“Wells Fargo”) following Wells

Fargo’s undisputed wrongful denial of their request for a loan modification pursuant to the Home

Affordable Modification Program (“HAMP”). The Complaint claims common-law fraud and both

negligent and intentional infliction of emotional distress (“NIED” and “IIED,” respectively) under

Kentucky law. The district court granted Wells Fargo’s motion to dismiss all of the Wests’ claims,

finding that despite the bank’s admission that it wrongfully denied the Wests’ loan modification,

each of their state-law claims fail because they failed to show causation. The district court Case No. 20-6381, West v. Wells Fargo Bank, N.A.

interpreted Kentucky law on causation to require the Wests to allege that if Wells Fargo had

approved them for a Trial Period Plan (“TPP”)—a prerequisite to obtaining a permanent loan

modification—they would have satisfied the requirements of the TPP and Wells Fargo would have

approved them for a loan modification, in order to overcome a motion to dismiss. But the Wests’

Complaint makes no such claim, so the district court granted the motion to dismiss.

We find that the claims fail at an earlier stage of the inquiry, and for the reasons set forth

below, we affirm the judgment of the district court.

I.

When reviewing a lower court’s order dismissing an action under Federal Rule of Civil

Procedure 12, this court applies a de novo standard and accepts all well-pleaded facts in the

Complaint as true. See Mik v. Fed. Home Loan Mortg. Corp., 743 F.3d 149, 156-57 (6th Cir.

2014). The court may also consider documents attached to the Complaint and take judicial notice

of public records. See Jackson v. City of Columbus, 194 F.3d 737, 745 (6th Cir. 1999) (The court

may consider public records and matters of which a court may take judicial notice.), abrogated on

other grounds by Swierkiewicz v. Sorema, 534 U.S. 506 (2002). The court does so here both to

provide background and to summarize the operation of HAMP.

The Home Affordable Mortgage Program

During the early and mid-2000s, the housing market and mortgage industry in the United

States underwent substantial growth. But both the rate of growth and stability of the market were

unsustainable, resulting in a housing bubble that burst around 2008, causing housing values to

sink. Many Americans found themselves upside down on their mortgages, meaning they owed

more than the value of their homes, and a significant number faced foreclosure due to defaults. In

response, Congress enacted the Emergency Economic Stabilization Act, Pub. L. No. 110–343, 122

-2- Case No. 20-6381, West v. Wells Fargo Bank, N.A.

Stat. 3765, to “provid[e] stability to and prevent[] disruption in the economy and financial

system. . . .” Among other things, the Act authorized the Secretary of the Treasury to “use loan

guarantees and credit enhancements to facilitate [mortgage] loan modifications to prevent

avoidable foreclosures.” 12 U.S.C. § 5219(a). Pursuant to this authority, the Secretary created

HAMP, which incentivizes loan servicers to help homeowners avoid foreclosure by refinancing

mortgages at interest rates more favorable to borrowers. Id. The Secretary provides monetary and

other incentives to participating loan servicers each time the servicer agrees to modify a loan under

the program.

In Supplemental Directive 09-01, the Secretary provides criteria, and offers optional

software, for loan servicers to use to determine borrowers’ eligibility for HAMP.1 Loan servicers

may also use their own software to evaluate borrowers under the same criteria. Id. If a borrower

meets the criteria, the Secretary directs that participating loan servicers “MUST offer the

modification.” Id. at 4.

The modification process consists of two stages: First a TPP, then a permanent loan

modification. Id. at 18. After a loan servicer determines that a borrower is eligible, the borrower

must comply with the terms of a TPP agreement, which requires the borrower to make payments

in specified amounts and provide documentation in a manner similar to the loan servicing

requirements for loans in forbearance. Id. If the borrower complies with the TPP terms, the

permanent loan automatically goes into effect at the end of the trial period. Id.

1 See U.S. Dep’t of Treasury, Supp. Dir. 09-01, at 5 (Apr. 9, 2009), available at: https://www.hmpadmin.com/portal/programs/docs/hamp_servicer/sd0901.pdf (last accessed Aug. 31, 2022).

-3- Case No. 20-6381, West v. Wells Fargo Bank, N.A.

Wells Fargo’s Participation in HAMP

Wells Fargo was a loan servicer participant in HAMP at all times relevant to this lawsuit.

It elected to use its own software, rather than the optional software provided by the Secretary, to

determine borrowers’ eligibility for loan modifications. The bank, however, did not audit its

software to verify the accuracy of its eligibility determinations in accordance with the criteria set

forth by the Secretary. In fact, the Office of the Comptroller of the Currency (“OCC”) investigated

Wells Fargo in 2010 and found that it “failed to devote adequate oversight to its foreclosure

processes, failed to ensure compliance with applicable laws, and failed to adequately audit its

foreclosure procedures.” After the investigation, Wells Fargo signed two consent orders in 2011

pledging “to maintain adequate governance and controls to ensure compliance with HAMP; to

engage in ongoing testing for compliance with HAMP; and to ensure that the bank’s mortgage

modification and foreclosure practices were regularly reviewed and any deficiencies promptly

detected and remedied.” Wells Fargo also agreed that a Compliance Committee and an Audit and

Examination Committee, comprised of its board members, would monitor its compliance with the

consent orders.

Nevertheless, in June 2015, about four years after Wells Fargo signed the consent orders,

the OCC found that Wells Fargo had not been complying with the orders. Errors stemming from

this noncompliance led Wells Fargo to wrongfully deny mortgage modifications to 184 borrowers

between 2013 and 2014. The OCC noted several compliance issues, including that Wells Fargo

had not ensured that its audit and compliance programs were sufficient to identify and promptly

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