PHOUNG T. NGUYEN v. BANK OF AMERICA CORPORATION

CourtCourt of Appeals of Georgia
DecidedJune 17, 2025
DocketA25A0424
StatusPublished

This text of PHOUNG T. NGUYEN v. BANK OF AMERICA CORPORATION (PHOUNG T. NGUYEN v. BANK OF AMERICA CORPORATION) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
PHOUNG T. NGUYEN v. BANK OF AMERICA CORPORATION, (Ga. Ct. App. 2025).

Opinion

THIRD DIVISION DOYLE, P. J., MARKLE and PADGETT, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

June 17, 2025

In the Court of Appeals of Georgia A25A0424. NGUYEN v. BANK OF AMERICA CORPORATION et al.

DOYLE, Presiding Judge.

Mortgage borrower Phoung Nguyen sued Bank of America Corporation

(“BOA”); the Federal National Mortgage Association (“FNMA”); Ditech Financial,

LLC (“Ditech”); NewRez, LLC; and McCalla Raymer Leibert Pierce, LLC

(“McCalla”), asserting various claims stemming from their alleged wrongful

foreclosure on her house. After the defendants moved to dismiss the claims under

OCGA § 9-11-12 (b) (6), the trial court entered an order that unwound the foreclosure

and restored her title (subject to the original security deed) and dismissed her

remaining claims as moot. Nguyen now appeals, contending that the trial court erred by holding that all of her claims were mooted by the restoration of her title. For the

reasons that follow, we agree in part.

“We review the trial court’s denial of a motion to dismiss for failure to state a

claim de novo, construing the complaint in the plaintiff’s favor.”1 So viewed, the

record shows that in January 2004, Nguyen bought a home encumbered by a mortgage

from Countrywide Home Loans, Inc. In 2010, BOA and McCalla directed Nguyen to

pause her mortgage payments so that she could qualify for a mortgage assistance

program. Meanwhile, McCalla and BOA initiated a foreclosure of Nguyen’s home.

McCalla and BOA proposed a loan modification to Nguyen; however, they ultimately

foreclosed on the property, and title was transferred to BOA by a deed under power.

BOA then transferred title to FNMA, who was also represented by McCalla, and a

deed reflecting the transfer was recorded in May 2010.

Nguyen alleged in her complaint that she was unaware of the foreclosure, and

she eventually consummated the loan modification with BOA, which continued to

send her statements despite the fact that BOA already had obtained title and

1 Z-Space, Inc. v. Dantanna’s CNN Center, LLC, 349 Ga. App. 248, 248 (825 SE2d 628) (2019). 2 transferred the property to FNMA. During this time, Nguyen continued to make her

mortgage payments to BOA.

In 2011, BOA transferred the mortgage to Greentree Mortgage Company L/P,

which later transferred the mortgage to defendant Ditech. Nguyen continued to make

mortgage payments to Greentree and Ditech throughout this time. Ditech then

transferred the mortgage to defendant New Rez, which began collecting mortgage

payments from Nguyen.

In 2019, Nguyen attempted to sell her home and learned that she lacked title to

the home and could not close the sale. After Nguyen was unable to resolve the matter

with the defendants, she filed this action, enumerating claims for breach of contract

(Count 1), negligence (Count 2), wrongful foreclosure (Count 3), fraud (Count 4),

constructive fraud (Count 5), money had and received (Count 6), breach of fiduciary

duty (Count 7), unjust enrichment (Count 8), breach of implied covenant of good faith

and fair dealing (Count 9), conversion (Count 10), theft by deception (Count 11),

attorney fees (Count 12), and punitive damages (Count 13).

3 The defendants filed answers2 and motions to dismiss for failure to state a claim

under OCGA § 9-11-12 (b) (6). Following an untranscribed hearing in May 2023, the

trial court came to believe that the parties could settle the claims, so it invited them

to submit a proposed consent order. The parties were unable to agree on a proposed

order, so they eventually proposed separate orders, with each order including some

version of rescinding the foreclosure but not addressing all claims explicitly.3 In May

2024, the trial court entered an order styled as “Consent Order to Return Title.” The

order recounted that the parties had “consented to and agreed to the entry of this

Consent Order,” but it was signed only by the judge, not the parties. After ordering

that the foreclosure be unwound and the rights of the parties be returned to the

original status, the order concluded, “[t]he Court further FINDS that as a result of

dismissing this order [sic] the pending motions to dismiss are rendered MOOT. This

order shall resolve all issues in this case.”

Three days later, Nguyen moved the court to reconsider the order, noting her

lack of consent and stating: “[Nguyen] has never agreed to resolve all issues in this

2 Ditech filed a notice of bankruptcy. 3 In part, the proposed orders differed as to whether the defendants had acted “wrongfully.” 4 case upon the return of her wrongfully taken home.” The defendants responded,

acknowledging that Nguyen had not consented to the order, and they requested that

the court enter a modified order noting the lack of consent, preserving the unwinding

of the foreclosure, and dismissing the remaining claims with prejudice.

Thereafter, the trial court entered an order styled “Final Order to Return Title

of Property to Plaintiff.” The order substantively was the same as the original, but it

noted that it was “amended to correct a scrivener’s error that indicates that a

previously filed order was a consent order, when it was in fact intended by this Court

to be a Final Order.” The order concluded by summarily stating, “[t]he Court further

FINDS that as a result of dismissing this order [sic] the pending motions to dismiss

are rendered MOOT. This order shall resolve all issues in this case.” Nguyen now

appeals.

Nguyen contends that the trial court erred by holding that all of her claims were

mooted by the unwinding of the foreclosure. We agree in part.

As a threshold matter, we note that successfully moving to dismiss for failure

to state a claim is difficult by design.4

4 See generally Norman v. Xytex Corp., 310 Ga. 127, 130 (2) (848 SE2d 835) (2020) (“[T]he well-established test that must be satisfied before a motion to dismiss 5 A motion to dismiss for failure to state a claim upon which relief may be granted should not be sustained unless (1) the allegations of the complaint disclose with certainty that the claimant would not be entitled to relief under any state of provable facts asserted in support thereof; and (2) the movant establishes that the claimant could not possibly introduce evidence within the framework of the complaint sufficient to warrant a grant of the relief sought. In deciding a motion to dismiss, all pleadings are to be construed most favorably to the party who filed them, and all doubts regarding such pleadings must be resolved in the filing party’s favor. In other words, a motion to dismiss for failure to state a claim should not be granted unless it appears to a certainty that the plaintiff would be entitled to no relief under any state of facts which could be proved in support of his claim. If, within the framework of the complaint, evidence may be introduced which will sustain a grant of relief to the plaintiff, the complaint is sufficient.5

As noted above, Nguyen has filed claims for breach of contract (Count 1),

negligence (Count 2), wrongful foreclosure (Count 3), fraud (Count 4), constructive

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