Patel v. Patel

CourtCourt of Appeals of North Carolina
DecidedJuly 16, 2024
Docket23-924
StatusPublished

This text of Patel v. Patel (Patel v. Patel) is published on Counsel Stack Legal Research, covering Court of Appeals of North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patel v. Patel, (N.C. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF NORTH CAROLINA

No. COA23-924

Filed 16 July 2024

Forsyth County, No. 21 CVS 5644

DHIRAJLAL C. PATEL, Plaintiff,

v.

KIRAN S. PATEL, SANDIP PATEL, and SHIV INVESTMENTS, INC., Defendants.

Appeal by Defendants from order entered 11 May 2023 by Judge Eric Morgan

in Forsyth County Superior Court. Heard in the Court of Appeals 20 February 2024.

James, McElroy & Diehl, P.A., by Alexandra B. Bachman, Preston O. Odom, III, and J. Alexander Heroy, for the Plaintiff-Appellee.

Bennett Guthrie PLLC, by Joshua H. Bennett and Mitchell H. Blankenship, for the Defendants-Appellants.

GRIFFIN, Judge.

Defendants Kiran S. Patel, Sandip Patel, and Shiv Investments, Inc., appeal

from the trial court’s order granting judgment on the pleadings to Plaintiff Dhirajlal

C. Patel in his action to renew a prior judgment for collection of debts owed by

Plaintiff and Defendants on a commercial loan. Defendants contend the trial court

erred because Plaintiff was a co-debtor who owed the same judgment he was seeking

to collect and was therefore barred from collecting on the judgment. We hold the facts

undisputably show Plaintiff is equitably barred from enforcing the judgment, and

therefore reverse the trial court’s order. PATEL V. PATEL

Opinion of the Court

I. Factual and Procedural Background

In 2011, Bank of the Carolinas (the “Bank”) filed a complaint against Plaintiff

and Defendants alleging that they had all committed breach of contract, as obligors

or guarantors, with respect to defaulted payments owed for two commercial loans.

On 18 September 2012, the trial court granted summary judgment in favor of the

Bank and against both Plaintiff and Defendants (the “2012 Bank Judgment”).

On 22 July 2013, the Bank assigned its right to enforce the 2012 Bank

Judgment to Plaintiff in exchange for consideration less than the total value of the

judgment, even though he was a debtor to the debt owed therein, and expressed at

that time that “no part of the [2012 Bank Judgment] has been previously paid,

assigned, or transferred.” Between July 2013 and November 2021, Plaintiff acted on

his position as assignee and owner of the 2012 Bank Judgment and collected varying

payments on it from Defendants.

On 9 November 2021, Plaintiff filed a complaint initiating the present action

against Defendants, seeking to renew and enforce the 2012 Bank Judgment. All

Defendants filed answers to Plaintiff’s complaint. On 23 February 2023, Plaintiff

filed a motion for judgment on the pleadings or, alternatively, summary judgment.

On 27 March 2023, Defendants also filed a motion for judgment on the pleadings, as

well as a motion to compel.

On 10 April 2023, the trial court held a virtual hearing on Plaintiff and

Defendant’s motions over WebEx. On 11 May 2023, the trial court entered a written

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order granting Plaintiff’s motion for judgment on the pleadings. Defendants timely

appeal.

II. Analysis

Defendants contend the trial court erred by granting Plaintiff’s motion for

judgment on the pleadings in his action to renew the 2012 Bank Judgment, and by

denying their motion for the same, because its decision turns on an error of law.

Defendants argue judgment on the pleadings for Plaintiff was improper because

Plaintiff is a co-debtor under the judgment, rendering it unenforceable. Plaintiff

refutes Defendants’ contention, and also asserts that Defendants wage an untimely

collateral attack on the 2012 Bank Judgment’s enforceability.

“We review de novo the trial court’s order granting judgment on the pleadings.”

Old Republic Nat’l Title Ins. Co. v. Hartford Fire Ins. Co., 369 N.C. 500, 507, 797

S.E.2d 264, 269 (2017) (citation omitted). “In deciding whether to grant or deny a

motion for judgment on the pleadings, the trial court is required to view the facts and

permissible inferences in the light most favorable to the nonmoving party, with all

well pleaded factual allegations in the nonmoving party’s pleadings being taken as

true and all contravening assertions in the movant’s pleadings being taken as false.”

Anderson Creek Partners, L.P. v. Cnty. of Harnett, 382 N.C. 1, 12, 876 S.E.2d 476

(cleaned up), 485, reh'g denied, ___N.C. ___, 878 S.E.2d 145 (2022). “A party seeking

judgment on the pleadings must show that the complaint fails to allege facts

sufficient to state a cause of action or admits facts which constitute a complete legal

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bar thereto.” DiCesare v. Charlotte-Mecklenburg Hosp. Auth., 376 N.C. 63, 70, 852

S.E.2d 146, 151 (2020) (cleaned up).

To renew the enforceability of a prior judgment, the owner of the judgment

may bring an independent action alleging “[1] the existence of a prior judgment

against the defendant; [2] the fact that full payment on the judgment has not been

made; and [3] an accounting of the unpaid balance due and any applicable interest.”

Unifund CCR Partners v. Young, 282 N.C. App. 381, 386, 871 S.E.2d 347, 351 (2022).

Defendants do not challenge Plaintiff’s assertions that the 2012 Bank Judgment was

never fully paid, or the amount of the alleged unpaid balance. Defendants argue only

that, even considering the pleadings in the light most favorable to Plaintiff, Plaintiff

cannot successfully show the existence of a prior judgment.

In their efforts to guide our resolution of this issue, Plaintiff and Defendants

each assert that one of two cases of North Carolina precedent should control: Hoft v.

Mohn, 215 N.C. 397, 2 S.E.2d 23 (1939), and Unifund CCR Partners v. Hoke, 273 N.C.

App. 401, 848 S.E.2d 508 (2020).

Plaintiff relies on Unifund CCR Partners v. Hoke. The trial court specifically

cited Hoke in its order granting Plaintiff’s motion for judgment on the pleadings. In

Hoke, the plaintiff purchased a credit account including debts owed by the defendant,

then obtained a judgment against the defendant to collect those debts. Ten years

later, the plaintiff sought to renew its judgment against the defendant. Hoke, 273

N.C. App. at 402, 848 S.E.2d at 509. The defendant argued that the plaintiff, in

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bringing its renewal action, failed to satisfy heightened pleading requirements

associated with its status as a “debt buyer.” Id. at 403, 848 S.E.2d at 509. The court

disagreed with the defendant’s argument and otherwise held no genuine issues of

material fact existed because the defendant did “not challenge the existence or

validity of the judgment, nor the validity of the underlying debt.” Id. at 406, 848

S.E.2d at 511. In reaching its holding that the plaintiff was not a “debt buyer,” the

court clarified that, “[b]ecause a claim was already filed and a judgment was

rendered, the action [then] before this Court involve[d] that judgment and not the

underlying debt claim.” Id. at 405, 848 S.E.2d at 511. Therefore, the only evidence

of the defendant’s debt, which was material to the renewal action, was the judgment

being renewed. Id. at 405, 848 S.E.2d at 511.

We hold Hoke to have limited application to the present case. Here,

Defendants do challenge the existence of the 2012 Bank Judgment and do not make

any assertions that Plaintiff failed to comply with statutorily heightened pleading

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Hoft v. . Mohn
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Towe v. . Felton
52 N.C. 216 (Supreme Court of North Carolina, 1859)
Old Republic National Title Insurance Co. v. Hartford Fire Insurance Co.
797 S.E.2d 264 (Supreme Court of North Carolina, 2017)
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Holcomb v. Holcomb
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Patel v. Patel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patel-v-patel-ncctapp-2024.