Mercantile Bank v. Hurowitz, No. Cv 95 0381091 S (May 2, 2000)

2000 Conn. Super. Ct. 5247
CourtConnecticut Superior Court
DecidedMay 2, 2000
DocketNo. CV 95 0381091 S
StatusUnpublished

This text of 2000 Conn. Super. Ct. 5247 (Mercantile Bank v. Hurowitz, No. Cv 95 0381091 S (May 2, 2000)) is published on Counsel Stack Legal Research, covering Connecticut Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mercantile Bank v. Hurowitz, No. Cv 95 0381091 S (May 2, 2000), 2000 Conn. Super. Ct. 5247 (Colo. Ct. App. 2000).

Opinion

[EDITOR'S NOTE: This case is unpublished as indicated by the issuing court.]

MEMORANDUM OF DECISION
On November 28, 1995, the plaintiff, Mercantile Bank of St. Louis, filed the present complaint in foreclosure against the defendants, Doreen T. Hurowitz and Larry Steven Hurowitz (the defendants). The plaintiff alleges that on March 30, 1987, the defendant Doreen T. Hurowitz became indebted in the amount of $210,000 to Citicorp Person-To-Person Financial Center of Connecticut, Inc. The defendant Doreen T. Hurowitz executed a promissory note in favor of Citicorp Person-To-Person, which promissory note was secured by a mortgage on real property in Wallingford, Connecticut. The plaintiff further alleges that the mortgage was assigned to Citicorp Mortgage Inc. which reassigned the mortgage to the present plaintiff. The plaintiff further alleges that the defendant Doreen T. Hurowitz defaulted on the April 1, 1994 payment and that said default has not been cured. The plaintiff has given notice of the present foreclosure action by causing a lis pendens to be filed on the town of Wallingford land records.

On March 11, 1997, the defendants filed an amended answer with twelve special defenses and a sixteen-count counterclaim.

On July 8, 1998, the plaintiff filed a motion to strike the defendants' special defenses and counterclaims and two memoranda of law in support. The defendants have filed a memorandum in opposition.

"Whenever a party wishes to contest . . . the legal sufficiency of . . . a special defense, . . . that party may do so by filing a motion to strike. . . ." Practice Book § 10-39. "In ruling on the . . . motion to strike, the trial court . . . [has an] obligation to take the facts to be those alleged in the special defenses and to construe the defenses in the manner most favorable to sustaining their legal sufficiency." Connecticut National Bank v. Douglas, 221 Conn. 530,536, 606 A.2d 684 (1992). CT Page 5248

"The purpose of a special defense is to plead facts that are consistent with the allegations of the complaint but demonstrate, nonetheless, that the plaintiff has no cause of action." (Internal quotations marks omitted.) Danbury v. Dana Investment Corp.,249 Conn. 1, 17, ___ A.2d ___ (1999).

The plaintiff moves to strike all twelve of the defendants' special defenses on the ground that they are "neither valid nor legally sufficient defenses to a foreclosure action."

The defendants argue in opposition that each of their special defenses is legally sufficient because each "[attacks] the making, validity or enforcement of a modification of the note and mortgage, and thus the underlying loan documents. . . ."

"In a foreclosure action, defenses are generally limited to payment, discharge, release, satisfaction or invalidity of a lien. . . . In recognition that a foreclosure action is an equitable proceeding, courts have allowed mistake, accident, fraud, equitable estoppel, CUTPA, laches, breach of the implied covenant of good faith and fair dealing, tender of deed in lieu of foreclosure and a refusal to agree to a favorable sale to a third party to be pleaded as special defenses. . . . Other defenses which have been recognized are usury, unconscionability of interest rate, duress, coercion, material alteration, and lack of consideration." (Citations omitted; internal quotation marks omitted.) Norwest Mortgage v. Edwards, Superior Court, judicial district of Ansonia-Milford at Milford, Docket No. 057496 (May 4, 1998, Curran, J.) (22 Conn.L.Rptr. 123, 124). Additionally, under certain circumstances, inconsistent conduct on the part of the mortgagee may be deemed as a waiver of a right to accelerate the debt. See Christensen v. Cutaia, 211 Conn. 613,619-20, 560 A.2d 456 (1989).

"These special defenses have been recognized as valid special defenses where they were legally sufficient and addressed the making, validity or enforcement of the mortgage and/or note. The rationale behind this is that . . . special defenses which are not limited to the making, validity or enforcement of the note or mortgage fail to assert any connection with the subject matter of the foreclosure action and as such do not arise out of the same transaction as the foreclosure action. . . . Further, based on the same rationale, the defenses . . . cannot attack some act or procedure of the lienholder." (Citations omitted; internal quotation marks omitted.)Rinere v. M. Kalfus Building Design Corp., Superior Court, judicial district of New Haven at New Haven, Docket No. 388220 (January 30, CT Page 5249 1997, Celotto, S.T.R.); see Dime Savings Bank of New York, FSB v.Furey, Superior Court, judicial district of Ansonia-Milford at Milford, Docket No. 047557 (April 1, 1996, Curran, J.).

The defendants allege in their first special defense that the plaintiff misrepresented its intent to abide by a written stipulation agreement. Specifically, the defendants acknowledge that they defaulted on the subject note and that the plaintiff filed a prior foreclosure action on or before June 8, 1993. The defendants allege that the matter was resolved by written stipulation wherein the defendants agreed to make forbearance payments from October 1, 1993 through April 1, 1994 to cure the default. The defendants allege that the plaintiff agreed to reinstate and refinance the note at an "affordable rate." The defendants allege that they made payments pursuant to the agreement but that the plaintiff failed to reinstate or refinance the note. The defendants additionally allege that the plaintiff delayed applying the forbearance payments to the note for12-15 months, which delay caused interest, late charges and penalties to accrue against the defendants. The defendants conclude that the plaintiff's representations that it would reinstate and refinance the note and mortgage were untrue and that said representations were made to induce the defendants to make payments that the plaintiff would not have been entitled to under the note. The defendants further conclude that they relied to their detriment on said misrepresentations by making the payments and has been damaged.

In their second special defense, the defendants reallege the allegations of their first special defense and conclude that said conduct constitutes a breach of the plaintiff's obligation of good faith and fair dealing under the common law.

In their third special defense, the defendants reallege the allegations of the first special defense and conclude that said conduct constitutes a breach of the plaintiff's obligation as set forth under the Uniform Commercial Code (UCC); General Statutes § 42a-1-203.

In their fourth special defense, the defendants reallege the allegations of the first special defense and conclude that said conduct constitutes a breach of the plaintiff's duties under the stipulation agreement to refinance and/or modify the note.

In their fifth special defense, the defendants reallege the allegations of the first special defense and conclude that by virtue of the plaintiff's activities, the plaintiff is estopped from enforcing the subject note. CT Page 5250

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Christensen v. Cutaia
560 A.2d 456 (Supreme Court of Connecticut, 1989)
Connecticut National Bank v. Douglas
606 A.2d 684 (Supreme Court of Connecticut, 1992)
City of Danbury v. Dana Investment Corp.
730 A.2d 1128 (Supreme Court of Connecticut, 1999)
Fairfield Lease Corp. v. Romano's Auto Service
495 A.2d 286 (Connecticut Appellate Court, 1985)
Spicer v. Spicer
634 A.2d 902 (Connecticut Appellate Court, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
2000 Conn. Super. Ct. 5247, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mercantile-bank-v-hurowitz-no-cv-95-0381091-s-may-2-2000-connsuperct-2000.