PHH Mortgage Corp. v. Sanderson

CourtSuperior Court of Maine
DecidedJanuary 16, 2008
DocketCUMre-06-149
StatusUnpublished

This text of PHH Mortgage Corp. v. Sanderson (PHH Mortgage Corp. v. Sanderson) 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
PHH Mortgage Corp. v. Sanderson, (Me. Super. Ct. 2008).

Opinion

STATE OF MAINE ,~\<; :

ZUJU JAN I b P 3: ?~R~~~ ~O~ ~0~;':~0#6 PHH MORTGAGE CORPORATION, Plaintiff

v. ORDER ON PARTIES' MELINDA SANDERSON, CROSS MOTIONS FOR Defendant SUMMARY JUDGMENT

ANTHONY MANCINI, INC., FORTUNE CAPITAL GROUP, and COLONIAL ROAD CONDOMINIUM ASSOCIATION, Parties-in-Interest

Before the Court in this foreclosure action is Plaintiff PHH Mortgage

Corporation's Motion for Summary Judgment. 1 Also before the Court is Party­

in-Interest Anthony Mancini, Inc.'s Motion for Summary Judgment.

BACKGROUND Defendant Melinda Sanderson ("Sanderson") owns property located in

Portland, Maine. On December 23, 2005, Sanderson executed and delivered a

promissory note and mortgage on the property to NE Moves Mortgage, LLC.

NE Moves Mortgage, LLC then assigned the note and mortgage to Plaintiff PHH

Mortgage Corporation ("PHH Mortgage"). The note and mortgage were not a

construction loan or mortgage.

1 PHH Mortgage Corporation also moved for default judgment against Anthony Mancini, Inc. However, as it is clear that Mancini has in fact appeared and participated in this case and as PHH Mortgage has entered no further pleadings concerning its Motion for Default Judgment, the Court denies this Motion. Party-in-Interest Anthony Mancini, Inc. ("Mancini") alleges that it began

electrical work on Sanderson's property sometime in August 2005 as Sanderson

and her husband planned to turn a single-family home into a condominium

duplex. Mancini further alleges that it was readily apparent that demolition and

construction were occurring at the Portland property from August 2005 through

January 2006 as there was construction debris and a new deck being built at the

property during this time. It is undisputed that Mancini properly filed a

mechanics' lien against Sanderson's Portland property on January 24, 2006 in the

amount of $10,443.16.

On August 14, 2006, PHH Mortgage filed a Complaint to foreclose on

Sanderson's property. On September 27, 2006, Mancini's attorney responded to

an e-mail from PHH Mortgage's attorney regarding the order of priority by

stating that Mancini was not claiming priority over PHH Mortgage. Thereafter,

Mancini claims, it realized that it in fact was in position of first priority, not PHH

Mortgage. Currently pending before the Court is PHH Mortgage's Motion for

Summary Judgment on the foreclosure action with itself in the position of first

priority. Also pending is Mancini's Motion for Summary Judgment on the

foreclosure action with itself in the position of first priority. Both PHH Mortgage

and Mancini oppose the other's Motion.

STANDARD OF REVIEW

Summary judgment is proper where there exist no genuine issues of

material fact such that the moving party is entitled to judgment as a matter of

law. M.R. Civ. P. 56(c); Arrow Fastener Co., Inc. v. Wrabacon, Inc., 2007 ME 34,

IS, 917 A.2d 123, 126. "A court may properly enter judgment in a case when the

2 parties are not in dispute over the [material] facts, but differ only as to the legal

conclusion to be drawn from these facts." Tondreau v. Shenvin-Williams Co., 638

A.2d 728, 730 (Me. 1994). A genuine issue of material fact exists "when the

evidence requires a fact-finder to choose between competing versions of the

truth." Farrington's Owners' Ass'n v. Conway Lake Resorts, Inc., 2005 ME 93 1 9,

878 A.2d 504, 507. An issue of fact is material if it "could potentially affect the

outcome of the suit." Id. An issue is genuine if "there is sufficient evidence to

require a fact-finder to choose between competing versions of the truth at trial."

Lever v. Acadia Hasp. Corp., 2004 ME 35, 1 2, 845 A.2d 1178, 1179. If ambiguities

exist, they must be resolved in favor of the non-moving party. Beaulieu v. The

Aube Corp., 2002 ME 79,12,796 A.2d 683,685.

DISCUSSION

Mechanics' liens are available to "[w]hoever performs labor or furnishes

labor or materials ...used in erecting, altering, moving or repairing a house,

building or appurtenances ...by virtue of a contract with or by consent of the

owner" in order "to secure payment thereof." 10 M.R.S.A. § 3251 (2007). For

purposes of this statute, a mortgagee is considered an owner. Carey v. Boulette,

158 Me. 204, 206, 182 A.2d 473, 474 (1962). In this case, it is undisputed that

Mancini did not contract with PHH Mortgage to provide any labor or materials.

Accordingly, the question before this Court is whether or not PHH Mortgage

consented to Mancini's work within the meaning of the statute.

The Law Court has acknowledged that the question of consent is very

fact-specific and depends on the facts of each case. [d. at 207; 182 A.2d at 475 ("It

has been generally held that whether consent appears in any given case depends

3 wholly upon the facts in that case"). However, the Law Court has offered some

instruction for determining whether consent exists in a given case, including this

interpretation:

A mechanics' lien cannot have priority over the mortgage without knowledge on the part of the [mortgagee] of the nature and extent of the work being performed on the mortgaged premises. With such knowledge the conduct of the [mortgagee] will be examined to ascertain whether in the light of all the circumstances there is any basis for subordinating the mortgage to the lien claim, and if so, to what extent.

Gagnon's Hardware & Furniture, Inc. v. Michaud, 1998 ME 265,

194-94, quoting Carey, 158 Me. at 213, 182 A.2d at 478.

The Gagnon case involved facts similar to those in the instant case in that

Gagnon claimed that its mechanics' lien gave it first priority over the bank's

mortgage by virtue of the fact that a representative of the bank knew that the

property owner was going to make renovations to the property before the note

and mortgage were executed. Gagnon, 1998 ME 265,

point, the bank representative even met with a Gagnon employee to determine

the extent of the construction. Id.

knowledge that improvements were going to be made was sufficient consent by

the bank such that Gagnon had priority over the bank. Id.

The Law Court disagreed, holding that "[the bank] had insufficient knowledge of

the nature and extent of the work to establish consent. Even though [the bank]

had knowledge at the time of the closing of the intended conversion of the

property, it did not have knowledge of any specific details of the actual work to

be performed or of the actual delivery of goods and services subsequently made

by Gagnon's." Id.

4 In the instant case, Mancini has failed to substantiate his claim that PHH

Mortgage, or its predecessor NE Moves Mortgage, LLC, knew of or consented to

the work it was doing at the property. Indeed, the sole evidence Mancini

presents to the Court to support this assertion is the affidavit of its Vice President

Gino Mancini, who states that flit was readily apparent that demolition,

renovation and construction were occurring at the Property. Construction debris

from the demolition of existing walls, cabinets, etc. could be seen outside. A new

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Related

Gagnon's Hardware & Furniture, Inc. v. Michaud
1998 ME 265 (Supreme Judicial Court of Maine, 1998)
Lever v. Acadia Hospital Corp.
2004 ME 35 (Supreme Judicial Court of Maine, 2004)
Tondreau v. Sherwin-Williams Co.
638 A.2d 728 (Supreme Judicial Court of Maine, 1994)
Beaulieu v. the Aube Corp.
2002 ME 79 (Supreme Judicial Court of Maine, 2002)
Carey v. Boulette
182 A.2d 473 (Supreme Judicial Court of Maine, 1962)
Arrow Fastener Co., Inc. v. Wrabacon, Inc.
2007 ME 34 (Supreme Judicial Court of Maine, 2007)
Farrington's Owners' Ass'n v. Conway Lake Resorts, Inc.
2005 ME 93 (Supreme Judicial Court of Maine, 2005)

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PHH Mortgage Corp. v. Sanderson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phh-mortgage-corp-v-sanderson-mesuperct-2008.