PATRICK J. SEARS, Personal Representative v. SNR REALTY LLC.

CourtMassachusetts Appeals Court
DecidedJuly 2, 2025
Docket23-P-1290
StatusUnpublished

This text of PATRICK J. SEARS, Personal Representative v. SNR REALTY LLC. (PATRICK J. SEARS, Personal Representative v. SNR REALTY LLC.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PATRICK J. SEARS, Personal Representative v. SNR REALTY LLC., (Mass. Ct. App. 2025).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

23-P-1290

PATRICK J. SEARS, personal representative, 1

vs.

SNR REALTY LLC.

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The defendant, SNR Realty LLC (SNR), appeals from a final,

amended judgment entered in favor of Paul J. Sears on all claims

and counterclaims. We affirm.

Background. Sears executed his right to foreclose under a

mortgage to Steven Graziano to secure a loan on a condominium

unit located at 1079 Dickinson Street, Springfield (premises).

At the public foreclosure sale on March 29, 2018, SNR submitted

the highest bid of $147,000, inclusive of the five percent

buyer's premium. The memorandum of sale (contract) signed by

1Of the estate of Paul J. Sears. Sears passed away during the pendency of this appeal; his personal representative was substituted as the plaintiff by order of this court. Sears and attorney Sanjiv Reejhsinghani, the manager and owner

of SNR, required the parties to close by April 30, but allowed

Sears, in his "absolute and sole discretion," to extend the

closing date in certain circumstances for a limited period. As

required by the contract, SNR paid a total deposit of $14,700 to

Sears. In the contract, Reejhsinghani indicated he understood

that SNR would "forfeit" the deposit "should [he] fail to comply

with said terms and conditions of sale set forth therein."

On April 26, SNR notified Sears of potential title issues. 2

The parties continued to communicate past the closing date as

Sears's attorney attempted to resolve Reejhsinghani's concerns.

On May 1, Sears's attorney provided Reejhsinghani with the

results of his investigation. First, he indicated that notice

of the foreclosure had been given to all entitled to it. 3

Second, he informed Reejhsinghani that it was the purchaser's

2 Graziano had died before the foreclosure sale. Approximately one month before his death, Graziano had conveyed the premises to himself and to his wife as tenants by the entirety. In Reejhsinghani's view, an inchoate lien on the premises had arisen on Graziano's death that would last ten years, and the premises were thus subject to a future estate tax. Reejhsinghani also claimed that Sears had failed to give notice of the foreclosure sale to the estate tax division of the Massachusetts Department of Revenue (DOR).

3 Sears's attorney explained that as for the notice issue raised by Reejhsinghani, he had confirmed with an employee of a title insurance company that notice to the DOR was unnecessary where, as here, title had vested in the surviving tenant by the entirety before the initiation of foreclosure.

2 duty to resolve the estate tax lien issue. 4 Finally, he stated

Sears was prepared to convey marketable title as required by the

contract, and that Sears "expects to close" and requested a

date. On May 9, Reejhsinghani sent an e-mail message that

rejected that analysis, insisted that there was a notice issue

and that the title was not marketable, and requested, among

other things, that Sears remedy the estate tax lien issue before

he would agree to close.

Following additional failed attempts to resolve

Reejhsinghani's concerns, Sears's attorney stated that while he

disagreed with Reejhsinghani's analysis, to "resolve the dispute

and avoid litigation," he would drop the purchase price to

$135,000 (plus the buyer's premium) -- as long as the parties

closed by May 30. On May 30, Reejhsinghani rejected the price

reduction and notified Sears's attorney that since Sears could

no longer convey good title, "the sales agreement is void, and

[he] would require the full return of [his] deposit" that day.

In the meantime, while the parties continued to negotiate,

Sears's attorney resolved a tax taking with the city of

4 Sears's attorney suggested several ways Reejhsinghani could resolve the purported estate tax lien concern, and he pointed out that pursuant to the terms of the contract, the purchaser takes title subject to, inter alia, all liens. Attempting to assuage Reejhsinghani's concerns, Sears's attorney also informed him that the estate's lawyers had indicated that Graziano's estate would not be taxable.

3 Springfield. 5 On July 3, Sears's attorney informed Reejhsinghani

that the tax title issue had been resolved and Sears was "ready,

willing and able to convey"; he also asked Reejhsinghani whether

he was "prepared to close on the last terms discussed."

Reejhsingani was not.

In addition, even though Reejhsinghani had agreed to

purchase the premises subject to all "outstanding" tax titles

and municipal encumbrances of record, he took the position that

since these no longer existed, he was not responsible for them.

On July 9, Sears's attorney sent an e-mail message notifying

Reejhsinghani that due to his failure to remedy SNR's "continued

default" under the contract, Sears "shall convey [the premises]

to the second highest bidder and retain the deposit." 6

Reejhsinghani continued to try to wrangle a further reduction in

price. On July 13, Sears responded, holding firm on a price of

$135,000 "plus Buyers premium plus back taxes." He said if this

was not agreeable, he would release the deposit "upon execution

of a release and termination agreement." That same day,

Reejhsinghani sent an e-mail message accepting the $135,000

5 The city had obtained title to the premises on May 14 through a tax taking. On June 20, Sears's attorney recorded a "vacation of [the city's tax taking] judgment."

6 The mortgagee's notice of sale permitted the mortgagee to sell to the second highest bidder if the highest bidder defaulted. Sears submitted the second highest bid of $130,000.

4 reduced price, but refusing to pay the back taxes. 7

Reejhsinghani took this position even though he admits that

Sears's attorney had announced there was an outstanding tax lien

and unpaid condominium fees owed on the premises at the public

auction and the contract provided that the sale was subject to

back taxes. On July 23, Sears's attorney sent an e-mail message

to Reejhsinghani requesting that he either pick up the deposit

or send directions as to where it should be sent.

At this juncture, Sears, the second highest bidder, decided

to go forward with the purchase himself. However, Sears's

attorney made a mistake. Instead of conveying the property to

his client, Sears's attorney recorded a foreclosure deed on July

25, 2018, naming SNR as the grantee. Upon realizing the error,

Sears's attorney called Reejhsinghani the same day, but

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Cite This Page — Counsel Stack

Bluebook (online)
PATRICK J. SEARS, Personal Representative v. SNR REALTY LLC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/patrick-j-sears-personal-representative-v-snr-realty-llc-massappct-2025.