Merriweather v. Federal Home Loan Mortgage Corporation

CourtDistrict Court, E.D. Michigan
DecidedJune 3, 2025
Docket2:25-cv-10443
StatusUnknown

This text of Merriweather v. Federal Home Loan Mortgage Corporation (Merriweather v. Federal Home Loan Mortgage Corporation) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Merriweather v. Federal Home Loan Mortgage Corporation, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

GERALD MERRIWEATHER,

Plaintiff, Case No. 2:25-cv-10443

v. Hon. Brandy R. McMillion FEDERAL HOME LOAN United States District Judge MORTGAGE CORPORATION, et al.,

Defendants. __________________________________/

OPINION AND ORDER GRANTING DEFENDANTS’ MOTION TO DISMISS (ECF NO. 5)

Plaintiff Gerald Merriweather (“Merriweather”) brought this action under MICH. COMP. LAWS § 600.2932 for a single claim to quiet title on property he owned in Belleville, Michigan. See ECF No. 1. Before the Court is Defendants’ Federal Home Loan Mortgage Corporation, as a trustee for the benefit of the Freddie Mac Seasoned Credit Risk Transfer Trust Series 2021-3 (“Freddie Mac”), NewRez LLC, formally known as New Penn Financial LLC, doing business as, Shellpoint Mortgage Servicing (“Shellpoint”), New Residential Mortgage, LLC (“NRM”), and Ditech Financial LLC, formally known as Green Tree Servicing LLC (“Ditech”) (collectively, “Defendants”) Motion to Dismiss pursuant to Federal Rule 12(b)(6). ECF No. 5. The Motion has been fully briefed. ECF No. 22, 25. Having read the briefs, the Court finds that oral argument is unnecessary and will rule on the motion before it. E.D. Mich. L.R. 7.1(f)(2). For the reasons stated below, the Court GRANTS Defendants’ Motion to Dismiss.

I. On May 21, 2001, Merriweather and his wife Christina M. Merriweather were granted a mortgage by ABN AMRO Mortgage Group, Inc. (the “Mortgage”), which

encumbered the property that is the subject of this dispute. ECF No. 1-1, PageID.16. The Mortgage was recorded with the Wayne County, Michigan Register of Deeds on July 2, 2001. ECF No. 5, PageID.56. In the years that followed, the Mortgage was sold and assigned to several different entities.

In May 2016, Citimortgage, Inc., successor by merger to ABN AMRO Mortgage Group, Inc., assigned the Mortgage to Ditech. ECF No. 1-1, PageID.16. In March 2018, Ditech assigned the Mortgage to NRM. Id.; ECF No. 5, PageID.57.

In September 2019, NRM assigned the Mortgage to Shellpoint. ECF No. 1-1, PageID.16. In December 2023, Shellpoint assigned the mortgage to Freddie Mac. Id.

Merriweather alleges that at the time Ditech assigned the Mortgage to NRM, it was in Chapter 11 bankruptcy proceedings in the United States District Court for the Southern District of New York. Id. As a result, he alleges that the assignment was “unauthorized, invalid, and void ab initio.” Id. As a result, every other

subsequent assignment was also void. Id. In January 2025, Merriweather filed a complaint in state court that initiated this suit. Id. In the Complaint, Merriweather alleges that Ditech was not authorized

to assign the Mortgage to NRM in 2018 because it was subject to the automatic stay provisions under 11 U.S.C. § 362 because of its bankruptcy filing. ECF No. 1-1, PageID.16-17. As a result, he seeks to “quiet title and remove any adverse claims

by Defendants.” ECF No. 1-1, PageID.17. The case was removed to this Court on February 14, 2025. ECF No. 1. Defendants now move to dismiss this action because (1) Merriweather lacks standing to challenge the assignments, and (2) the Complaint fails to allege a plausible claim for quiet title under Michigan law. See ECF No. 5.

II. “To state a valid claim, a complaint must contain either direct or inferential allegations respecting all the material elements to sustain recovery under some

viable legal theory.” Boland v. Holder, 682 F.3d 531, 534 (6th Cir. 2012). In reviewing a 12(b)(6) motion, the Court “accept[s] all of the complaint’s factual allegations as true and determine[s] whether these facts sufficiently state a plausible

claim for relief.” Fouts v. Warren City Council, 97 F.4th 459, 464 (6th Cir. 2024) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555-56 (2007)). The Court “must ‘construe the complaint in the light most favorable to the plaintiff, accept all well- pleaded factual allegations as true, and examine whether the complaint contains

sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.’” Norris v. Stanley, 73 F.4th 431, 435 (6th Cir. 2023) (citations and internal quotation marks omitted).

Facial plausibility requires a plaintiff to “plead[] factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citation omitted).

“[T]hreadbare recitals of a cause of action’s elements, supported by merely conclusory statements” are insufficient to survive a motion to dismiss. Id. at 663. The court may consider “any exhibits attached to the complaint, public records, items appearing in the record of the case and exhibits attached to defendant’s motion

to dismiss so long as they are referred to in the complaint and are central to the claims contained therein.” Bassett v. NCAA, 528 F.3d 426, 430 (6th Cir. 2008). Courts must also liberally construe pro se complaints. See Boag v.

MacDougall, 454 U.S. 364, 365 (1982) (per curiam). And while pro se complaints, must be held to less stringent standards than formal pleadings drafted by lawyers, see Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam), pro se plaintiffs must still satisfy basic pleading requirements. See Hill v. Lappin, 630 F.3d 468, 470-71

(6th Cir. 2010). III. The Court reads Merriweather’s Complaint as a challenge to all of

Defendants’ interest in the property because Merriweather believes the assignment from Ditech to NRM in 2018 was void because it violated an automatic stay in Ditech’s bankruptcy proceedings; and as a result, all subsequent assignments were

likewise void. See ECF No. 1-1, PageID.16-17. He files this as an action to quiet title pursuant to MCL 600.2932. Id. at PageID.15. As a threshold matter, Defendants argue that “[t]he Sixth Circuit has

explained [] that ‘quiet title is a remedy, not a freestanding claim. Like a request for an injunction or disgorgement, a request for quiet title is only cognizable when paired with some recognized cause of action.’” See ECF No. 5, PageID.60-61; Haywood v. Roundpoint Mtge. Serv. Corp., No. 2:18-cv-10111, 2018 WL 3159624,

at *5 (E.D. Mich. June 28, 2018) (citing Jarbo v. Bank of N.Y. Mellon, 587 F.App’x 287, 290 (6th Cir. 2014)). The Court agrees and that is a basis to dismiss this action outright. However, in the “interest of completeness,” other courts in this district

have found the same to be true and still addressed the claim to quiet title. See Bell v. Cameron-Hall, No. 2:14-cv-11496, 2015 WL 4617424, at *4 (E.D. Mich. July 31, 2015) (collecting cases). In the spirit of construing pro se litigants’ pleadings liberally, see Erickson v. Pardus, 551 U.S. 89, 94 (2007), this Court will do the same.

A.

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

Related

Boag v. MacDougall
454 U.S. 364 (Supreme Court, 1982)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Dean Boland v. Eric Holder, Jr.
682 F.3d 531 (Sixth Circuit, 2012)
Bassett v. National Collegiate Athletic Ass'n
528 F.3d 426 (Sixth Circuit, 2008)
Carolyn Trombley v. Seterus, Inc.
614 F. App'x 829 (Sixth Circuit, 2015)
Bowles v. Oakman
225 N.W. 613 (Michigan Supreme Court, 1929)
Mark v. Bradford
23 N.W.2d 201 (Michigan Supreme Court, 1946)
Woods v. Ayres
39 Mich. 345 (Michigan Supreme Court, 1878)
Wiggins v. Argent Mortgage Co.
945 F. Supp. 2d 817 (E.D. Michigan, 2013)
Jeanna Norris v. Samuel Stanley, Jr.
73 F.4th 431 (Sixth Circuit, 2023)
James Fouts v. Warren City Council
97 F.4th 459 (Sixth Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Merriweather v. Federal Home Loan Mortgage Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/merriweather-v-federal-home-loan-mortgage-corporation-mied-2025.