Pettersen v. Countrywide Fin. Corp.

CourtSuperior Court of Maine
DecidedMarch 7, 2012
DocketCUMcv-12-09
StatusUnpublished

This text of Pettersen v. Countrywide Fin. Corp. (Pettersen v. Countrywide Fin. Corp.) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pettersen v. Countrywide Fin. Corp., (Me. Super. Ct. 2012).

Opinion

STATE OF MAINE BUSINESS AND CONSUMER COURT

Cumberland, ss. Dock. et No. rJ?-CV-12-09 A-M t1- CuM- ..:, "1 / 20 !1__ I i

TODD PETTERSEN

Plaintiff

v.

COUNTRYWIDE FINANCIAL CORPORATION as acquired by BANK OF AMERICA CORPORATION

Defendant

ORDER ON DEFENDANT'S MOTION TO DISMISS

The motion to dismiss filed by Defendant Countrywide Financial Corporation as

acquired by Bank Of America Corporation is before the court, together with Plaintiff Todd ·'

Petterson's opposition and Defendant's reply.

Background.

The Plaintiffs complaint asserts that Countrywide provided him with a residential

mortgage loan in 2005 at a higher interest rate than the rate quoted to him that induced him to

enter into the transaction. The complaint also asserts that Countrywide misled the Plaintiff

about the amount of his monthly payments-specifically that the payments included amounts

to fund an escrow account for taxes and insurance when in fact there was no escrow account

and the monthly payments covered only principal and interest on the loan. Plaintiff says he

was never told that the "exorbitant" fees and charges on his loan amounted to 3.5% of the

principal amount of the loan. Finally, the Plaintiff says that Countrywide represented that he

would be able to refinance and lower his monthly payment in six months, but never offered him

such an opportunity. As a result of the alleged misstatements and misrepresentations of Countrywide,

Plaintiff claims to have been unable to refinance and to be at risk of losing his home.

Plaintiffs complaint asserts that Defendant Bank of America, as successor in interest to

Countrywide, is liable on several distinct grounds:

• Count I of the complaint alleges that Countrywide's acts and omissions constitute

violations ofthe Maine Unfair Trade Practices Act (UTPA), 5 M.R.S. §§ 206-214

• Count II, III and IV allege violations of the Maine Consumer Credit Code, 9-A M.R.S .

§§ 9-401, 9-402, 10-101 et seq.

• Count V alleges intentional misrepresentation, i.e. fraud, under the common law and for

purposes of the Maine Consumer Credit Code

• Count VI alleges intentional and/ or negligent infliction of emotional distress

Defendant Bank of America, denies any liability and has moved to dismiss all of

Plaintiffs claims. 1

Standard if Review

A motion to dismiss "tests the legal sufficiency of the complaint." Livonia v. Town if

Rome, 1998 ME 39, ~ 5, 707 A.2d 83, 85. "Dismissal of a civil action is proper when the

complaint fails 'to state a claim upon which relief can be granted."' Bean v. Cummings, 2008 ME

18, ~ 7, 939 A.2d 676, 679 (citing M.R. Civ. P. 12(b)(6)). In determining whether a motion to

dismiss should be granted, the court considers "the allegations in the complaint in relation to

any cause of action that may reasonably be inferred from the complaint." Saunders v. Tisher,

2006 ME 94, ~ 8, 902 A.2d 830, 832.

1 In addition to the arguments summarized in this order, the Defendant argues that the Plaintiff is not entitled to the remedy of rescission even if he were to prevail on any of his claims, based on the passage of six years since the loan transaction. Defendant may well be correct, but rescission is a remedy and not a cause of action, and this Order does not address the nature or extent ofPlaintiffs potential recovery; it addresses only the viability ofhis claims as a matter oflaw.

2 The facts alleged are treated as admitted for purposes of the motion, and they are

viewed "in the light most favorable to the plaintiff" !d. The court should dismiss a claim only

"when it appears beyond a doubt that the plaintiff is not entitled to relief under any set of facts

that he [or she] might prove in support of his [or her] claim." !d. (quoting Johanson v.

Dunnington, 2001 ME 169, ~ 5, 785 A.2d 1244, 1246).

The Merits cifDifendant's Motion

Assessed under the very liberal standard applicable to motions to dismiss for failure to

state a claim under Rule 12(b)(6), most ofthe Plaintiffs claims are sufficient to withstand the

Defendant's motion. Many of the arguments on which the Defendant relies would be better

presented in a motion for summary judgment-some indication ofthat appears in the number

and variety of the references to outside materials-a state government website, loan

documents, the terms of a Consent Judgment--contained in the Defendant's memorandum.

Normally, when materials outside the pleadings are incorporated or referred to in a

Rule 12(b)(6) motion, the court must decide whether to consider or exclude the additional

materials, and ifthey are considered, the motion to dismiss is converted into a motion for

summary judgment. See Beaucage v. City if Rockland, 2000 ME 184, ~ 5, 760 A.2d 1054, 1056;

In re Magro, 655 A.2d 341, 342 (Me. 1995). See also M.R. Civ. P. 12(b) ("If, on a motion

asserting the defense numbered (6) to dismiss for failure of the pleading to state a claim upon

which relief can be granted, matters outside the pleading are presented to and not excluded by

the court, the motion shall be treated as one for summary judgment .... ").

However, the Law Court has recognized an exception to this general rule covering

three types ofmaterial outside the pleadings: "[O]fficial public documents, documents that are

central to the plaintiffs claim, and documents referred to in the complaint [can be considered]

without converting a motion to dismiss into a motion for a summary judgment when the

3 authenticity of such documents is not challenged." See Moody v. State Liquor and Lottery

Commission, 2004 ME 20, ~ 10, 843 A.2d 43, 48.

In the present case, the range of materials presented by Defendant is such that the court

elects to exercise its discretion not to consider them, and therefore limits its focus to the

relatively narrow question of whether, as a matter oflaw and viewed in a light most favorable

to the Plaintiff, each of the counts of the complaint states a claim upon which relief can be

granted.

Count I Maine's UTPA declares that "[u]nfair methods and unfair or deceptive acts or

practices in the conduct of any trade or commerce" are unlawful, 5 M.R.S. § 207, and provides a

cause of action for "[a]ny person who purchases or leases goods, services or property, real or

personal, primarily for personal, family or household purposes and thereby suffers any loss of

money or property, real or personal" as a result of unfair methods, acts, or practices, 5 M.R.S. §

213(1) (emphasis added).

The Maine Law Court has referred to the UTPA as a consumer protection statute. See

State v. Weinschenk, 2005 ME 28, ~ 11, 868 A.2d 200, 205 ("Maine's UTPA provides protection

for consumers against unfair and deceptive trade practices." (emphasis added) (citation omitted).

Because this was a residential loan transaction made to the homeowner, Plaintiffhas

standing under the UTPA. The court cannot say, as a matter oflaw based on the present

record, that a reasonable factfinder could not conclude that the acts and omissions alleged in

the complaint were deceptive or unfair for purposes of the UTPA. Defendant's emphasis on the

terms of the loan documents as overriding any contrary understanding on the Plaintiffs part

would be better presented in the context of a summary judgment motion. The motion to

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

Related

Moody v. State Liquor & Lottery Commission
2004 ME 20 (Supreme Judicial Court of Maine, 2004)
Saunders v. Tisher
2006 ME 94 (Supreme Judicial Court of Maine, 2006)
Beaucage v. City of Rockland
2000 ME 184 (Supreme Judicial Court of Maine, 2000)
In Re Magro
655 A.2d 341 (Supreme Judicial Court of Maine, 1995)
Bean v. Cummings
2008 ME 18 (Supreme Judicial Court of Maine, 2008)
Jourdain v. Dineen
527 A.2d 1304 (Supreme Judicial Court of Maine, 1987)
Chapman v. Rideout
568 A.2d 829 (Supreme Judicial Court of Maine, 1990)
Livonia v. Town of Rome
1998 ME 39 (Supreme Judicial Court of Maine, 1998)
Johanson v. Dunnington
2001 ME 169 (Supreme Judicial Court of Maine, 2001)
State v. Weinschenk
2005 ME 28 (Supreme Judicial Court of Maine, 2005)

Cite This Page — Counsel Stack

Bluebook (online)
Pettersen v. Countrywide Fin. Corp., Counsel Stack Legal Research, https://law.counselstack.com/opinion/pettersen-v-countrywide-fin-corp-mesuperct-2012.