Pearson v. Specialized Loan Servicing

CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 30, 2022
Docket22-20005
StatusUnpublished

This text of Pearson v. Specialized Loan Servicing (Pearson v. Specialized Loan Servicing) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pearson v. Specialized Loan Servicing, (5th Cir. 2022).

Opinion

Case: 22-20005 Document: 00516452752 Page: 1 Date Filed: 08/30/2022

United States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit

FILED August 30, 2022 No. 22-20005 Lyle W. Cayce Clerk

Tiffany Nicole Pearson,

Plaintiff—Appellant,

versus

Specialized Loan Servicing, L.L.C.,

Defendant—Appellee.

Appeal from the United States District Court for the Southern District of Texas USDC No. 4:20-CV-4044

Before Jones, Ho, and Wilson, Circuit Judges. Per Curiam:* Tiffany Nicole Pearson sued Specialized Loan Servicing, LLC (SLS), alleging that SLS violated the Texas Debt Collection Act by misstating the loan balance and foreclosure status of Pearson’s home in its payoff statement mailed to First American Title Guaranty Company. The district court granted summary judgment to SLS, and Pearson appeals. We affirm.

* Pursuant to 5th Circuit Rule 47.5, the court has determined that this opinion should not be published and is not precedent except under the limited circumstances set forth in 5th Circuit Rule 47.5.4. Case: 22-20005 Document: 00516452752 Page: 2 Date Filed: 08/30/2022

No. 22-20005

I. SLS was the mortgage servicer on Pearson’s mortgage. On December 30, 2019, after Pearson defaulted on that mortgage, SLS sent notice to Pearson that it would be pursuing a non-judicial foreclosure on Pearson’s property on February 4, 2020. The sale proceeded on that date and the property was sold to GAMC, Inc. Pearson, purportedly unaware that the foreclosure sale had gone forward, contracted with Yuexin Wang to sell Wang the property. Pearson and Wang set a proposed closing date of February 17, 2020. First American was retained to insure Wang’s title and close the transaction. On February 10, 2020, First American sent a letter to SLS requesting that SLS provide First American a “demand” establishing the “amount necessary to pay [Pearson’s loan] obligation in full” through February 17, 2020. SLS sent First American a payoff statement the next day. It read: THIS STATEMENT REFLECTS THE TOTAL AMOUNT DUE UNDER THE TERMS OF THE NOTE/SECURITY INSTRUMENT THROUGH THE CLOSING DATE WHICH IS 02/04/20 or the date the loan is transferred to a new servicer. If this obligation is not paid in full by this date, then you should request an updated payoff amount before closing. The statement provided that, as of February 4, 2020, the “Total Amount Due” was $125,448.73; that amount would accrue $23.4824 in interest per day should the balance not be paid by that day; and the payoff statement’s expiration date was February 4, 2020. At their closing on February 17, 2020, Pearson executed a warranty deed conveying the property to Wang. When it was later discovered that Pearson had no title to convey, First American paid on its insurance policy to Wang. First American then sued Pearson in Texas state court. Pearson in

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turn brought a third-party suit against SLS. Relevant to this appeal, Pearson alleged that SLS violated the Texas Debt Collection Act by “misrepresenting the character, extent, or amount of a consumer debt” in its February 11 payoff statement. Tex. Fin. Code § 392.304(a)(8). The cases were severed, and SLS removed Pearson’s suit against it to federal court. The district court granted summary judgment to SLS, concluding that SLS’s payoff statement did not contain any misrepresentations. Pearson timely appealed. II. We review a district court’s grant of summary judgment de novo. Hagen v. Aetna Ins. Co., 808 F.3d 1022, 1026 (5th Cir. 2015). Summary judgment is appropriate if the record evidence shows that there is no genuine issue of material fact and that the moving party is entitled to judgment as a matter of law. Fed. R. Civ. P. 56(a). Because we have diversity jurisdiction over this dispute and the underlying conduct, i.e., the sale of the property, occurred in Texas, we apply Texas law. See Erie R.R. Co. v. Tompkins, 304 U.S. 64, 78 (1938). III. Pearson challenges three aspects of the payoff statement: She contends that the payoff statement misrepresented (1) the amount owed, because the statement listed a closing date of February 4, 2020, rather than February 17, 2020; (2) that interest continued accruing after February 4; and (3) the foreclosure status of the property, by indicating interest would continue to accrue. Section 392.304(a)(8) of the Texas Finance Code prohibits a debt collector from “misrepresenting the character, extent, or amount of a consumer debt.” Thompson v. Bank of Am. Nat’l Ass’n, 783 F.3d 1022, 1026

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(5th Cir. 2014). A misrepresentation is “an affirmative statement that was false or misleading.” Id. (quoting Verdin v. Fed. Nat’l Mortg. Ass’n, 540 F. App’x 253, 257 (5th Cir. 2013) (per curiam)) (emphasis omitted). To prevail, Pearson must show that SLS “made a misrepresentation that led her to be unaware (1) that she had a mortgage debt, (2) of the specific amount she owed, or (3) that she had defaulted.” Rucker v. Bank of Am., N.A., 806 F.3d 828, 832 (5th Cir. 2015) (citing Miller v. BAC Home Loans Servicing, L.P., 726 F.3d 717, 723 (5th Cir. 2013)). Pearson contends that because the payoff statement calculated the loan payoff amount as of February 4, 2020, rather than February 17, 2020, as First American requested, SLS falsely represented that there was still a mortgage owed on the property. Texas law requires a payoff statement to “(1) state the proposed closing date for the sale and conveyance of the real property securing the home loan . . . and (2) provide a payoff amount that is valid through that date.” Tex. Fin. Code § 343.106(d). True enough, SLS’s payoff statement calculated the loan balance using the date of February 4, 2020 (the day the property was sold via foreclosure sale). But that error does not rise to an actionable misrepresentation under § 392.304(a)(8). While the date on the payoff statement may have been incorrect, nothing else was. The loan information in the payoff statement was not false or misleading: SLS accurately provided the loan balance through February 4, specified the per diem interest rate, and explicitly stated that the payoff statement expired on February 4. Pearson counters that even if the payoff statement contained “technically truthful statement[s],” it was nevertheless misleading because First American did not request “pre-foreclosure information” but rather asked for the payoff amount as of February 17, 2020. She reasons that SLS’s decision to send pre-foreclosure information without explanation was

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misleading because the statement should have reported that there was no payoff balance after the February 4 foreclosure sale. Perhaps such an explanation would have helped Pearson understand the property’s foreclosure status before she executed a warranty deed in favor of Wang.

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Related

Erie Railroad v. Tompkins
304 U.S. 64 (Supreme Court, 1938)
James Miller v. BAC Home Loans Servicing, L
726 F.3d 717 (Fifth Circuit, 2013)
Adrian Verdin v. Federal Natl Mortgage Assoc, et a
540 F. App'x 253 (Fifth Circuit, 2013)
David Thompson v. Bank of America N.A., et
783 F.3d 1022 (Fifth Circuit, 2015)
Diana Rucker v. Bank of America, N.A.
806 F.3d 828 (Fifth Circuit, 2015)
Judy Hagen v. Aetna Insurance Company
808 F.3d 1022 (Fifth Circuit, 2015)
Douglas v. Wells Fargo Bank
992 F.3d 367 (Fifth Circuit, 2021)

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Bluebook (online)
Pearson v. Specialized Loan Servicing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pearson-v-specialized-loan-servicing-ca5-2022.