Mulligan v. Choice Mortgage

CourtDistrict Court, D. New Hampshire
DecidedAugust 11, 1998
DocketCV-96-596-B
StatusPublished

This text of Mulligan v. Choice Mortgage (Mulligan v. Choice Mortgage) 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
Mulligan v. Choice Mortgage, (D.N.H. 1998).

Opinion

Mulligan v. Choice Mortgage CV-96-596-B 08/11/98 P

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Michael Mulligan and Patricia Mulligan; for themselves and on behalf of all others similarly situated

v. Civil No. 96-596-B

Choice Mortgage Corp. USA

MEMORANDUM AND ORDER

Michael and Patricia Mulligan (the "Mulligans") bring this

class action complaint against Choice Mortgage Corp. USA

("Choice" ) , alleging violations of the Real Estate Settlement

Procedures Act ("RESPA"), 12 U.S.C.A. § 2607 (West 1989 & Supp.

1998), the Racketeer Influenced and Corrupt Organizations Act

("RICO"), 18 U.S.C.A. § 1961 et seg. (West 1994 & Supp. 1998),

and New Hampshire's Consumer Protection Act, N.H. Rev. Stat. Ann.

§ 358-A:2 et seg. (1995). The Mulligans also assert that Choice

breached the fiduciary duty it owed to class members, breached

the terms of its contracts with class members, and committed

common-law fraud. The Mulligans now move pursuant to Fed. R.

Civ. P. 23 to certify a class of 113 individuals who entered into

residential mortgage transactions in which Choice served as the

mortgage broker and received payments from both the borrower and

the lender. For the reasons discussed below, I grant the

Mulligans' motion in part and deny it in part. I. BACKGROUND

The Mulligans decided to refinance their home mortgage in

early 1996. To that end, they signed an agreement with Choice, a

mortgage broker, to find them a suitable lender. The agreement

specified that Choice would "endeavor to provide [the Mulligans]

with the best possible loan program for [their] specific needs."

In return, the Mulligans agreed to pay Choice a 3% brokerage fee

and an amount to cover its administrative costs. Choice

eventually secured a mortgage loan for the Mulligans in the

amount of $124,000 from Long Beach Mortgage Company ("Long

Beach"), a California mortgage lender. At the closing, the

Mulligans paid Choice a $3,720 brokerage fee plus an additional

$850 to cover application, document, and processing fees.

The Mulligans allege that, unbeknownst to them. Choice also

received a payment of $3,720 from Long Beach in exchange for

referring the Mulligans to Long Beach for a mortgage loan at an

interest rate higher than that at which Long Beach otherwise

would have made the loan. The Mulligans assert that this

payment, which the parties refer to as a "yield spread premium"

or "YSP," is either a "referral fee" or a "duplicative charge,"

2 both of which are prohibited by RESPA, 12 U.S.C.A. § 2607 (a)&(b),

and its implementing regulations, 24 C.F.R. § 3500 et seg.

(1997).1 They also allege that Choice's inadeguately disclosed

practice of accepting YSPs in exchange for referring borrowers to

mortgage lenders violates RICO, 18 U.S.C.A. § 1961 et se g ., and

New Hampshire's Consumer Protection Act, N.H. Rev. Stat. Ann. §

358-A:2 et seg., and gives rise to various common-law causes of

action.

The Mulligans contend that their claims are part of a

pattern of misconduct by Choice involving at least 72 other loan

transactions and 113 individuals. Accordingly, they seek to

certify a plaintiffs' class of all persons who entered into a

residential mortgage loan transaction in which Choice acted as

1 Mortgage lenders typically send brokers a daily rate sheet setting forth the "par" interest rate at which they will enter into a mortgage loan with a certain class of borrower. Lenders routinely pay an "overage," a type of payment of which a YSP is a particular variety, to brokers who bring in a mortgage loan at an interest rate above that "par" rate. See Robert M. Jaworski, Overages: To Pay or Not to Pay, That is the Question, 113 Banking L.J. 909, 910 (1996) . The amount of a YSP typically is calculated according to a formula based on the differential between the actual interest rate at which the loan closed and the lender's "par" interest rate. Id.; Culpepper v. Inland Mortgage Corp., 132 F.3d 692, 694 (11th Cir. 1998).

3 the broker and received payments from both the borrower and the

lender.

II. CLASS CERTIFICATION STANDARDS

To certify a proposed class, the Mulligans first must

satisfy the four prerequisites of Rule 23 (a) by showing that

(1) the class is so numerous that joinder of all members is impractical, (2) there are questions of law or fact common to the class, (3) the claims or defenses of the representative parties are typical of the claims or defenses of the class, and (4) the representative parties will fairly and adequately protect the interests of the class.

Fed. R. Civ. P. 23(a). The first two prerequisites, numerosity

and commonality, require the named plaintiffs to show that an

identifiable class exists. The second two, typicality and

adequacy, require the named plaintiffs to establish that they are

appropriate representatives of the proposed class. See Rules

Advisory Comm. Note to Amended Rule 2 3 , 39 F.R.D. 98,100 (1966);

1 Herbert Newberg & Alba Conte, Newberg on Class Actions, §3.01

(3d ed. 1992) ("Newberg"). If these requirements are satisfied,

the class then must also meet the characteristics of at least one

of the three categories provided in Rule 2 3 (b), which allows

class actions where: (1) separate actions by or against

individual class members would risk imposing inconsistent

obligations on the party opposing the class; (2) "the party

4 opposing the class has acted or refused to act on grounds

generally applicable to the class" and injunctive relief is

appropriate; or (3) common guestions of law or fact predominate

and a class action would be the superior method of proceeding.

Fed. R. Civ. P. 23(b)(l)-(3). The Mulligans bear the burden of

establishing all of the reguirements for class certification.

Makuc v. American Honda Motor Co . , 835 F.2d 389, 394 (1st Cir.

1987) .

Although the Supreme Court has stated that a court should

not decide the merits of a case at the class certification stage,

Eisen v. Carlisle & Jacguelin, 417 U.S. 156, 177-78 (1974), a

motion to certify "generally involves considerations . . .

enmeshed in the factual and legal issues comprising [a]

plaintiff's cause of action." Coopers & Lybrand v. Livesav, 437

U.S. 463, 469 (1978) (internal guotations omitted) (guoting

Mercantile Nat'l Bank v. Langdeau, 371 U.S. 555, 558 (1963)).

This is particularly true with respect to guestions of

predominance and superiority which necessitate a "close look" at,

inter alia, "the difficulties likely to be encountered in the

management of a class action." Amchem Prods., Inc. v. Windsor,

117 S. C t . 2231, 2246 (1997); Manual for Complex Litiaation §

30.11 (3d ed. 1995).

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