Princeton South Investors, LLC v. First American Title Insurance Insurance Company

97 A.3d 1190, 437 N.J. Super. 283
CourtNew Jersey Superior Court Appellate Division
DecidedSeptember 8, 2014
DocketA-0850-12
StatusPublished
Cited by3 cases

This text of 97 A.3d 1190 (Princeton South Investors, LLC v. First American Title Insurance Insurance Company) is published on Counsel Stack Legal Research, covering New Jersey Superior Court Appellate Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Princeton South Investors, LLC v. First American Title Insurance Insurance Company, 97 A.3d 1190, 437 N.J. Super. 283 (N.J. Ct. App. 2014).

Opinion

NOT FOR PUBLICATION WITHOUT THE APPROVAL OF THE APPELLATE DIVISION

SUPERIOR COURT OF NEW JERSEY APPELLATE DIVISION DOCKET NO. A-0850-12T3

PRINCETON SOUTH INVESTORS, LLC, APPROVED FOR PUBLICATION Plaintiff-Appellant, September 8, 2014 v. APPELLATE DIVISION FIRST AMERICAN TITLE INSURANCE COMPANY,

Defendant-Respondent. _________________________________

Argued January 22, 2014 – Decided September 8, 2014

Before Judges Reisner, Ostrer and Carroll.

On appeal from the Superior Court of New Jersey, Law Division, Mercer County, Docket No. L-3122-11.

Brian P. Flaherty of the Pennsylvania Bar, admitted pro hac vice, argued the cause for appellant (Cozen O'Connor, PC, attorneys; Mr. Flaherty and Diana J. Lin, on the brief).

Robert L. Grundlock, Jr., argued the cause for respondent (Rubin, Ehrlich & Buckley, PC, attorneys; Mr. Grundlock, on the brief).

The opinion of the court was delivered by

REISNER, P.J.A.D. In this insurance coverage dispute, plaintiff Princeton

South Investors (Princeton South or plaintiff) appeals from a

trial court order dated September 28, 2012, granting summary

judgment in favor of defendant First American Title Insurance

Company (First American). The case presents two issues: in the

context of a title insurance claim, whether a pending but as-

yet-undecided tax appeal by a municipality, asserting that a

property has been under-assessed, creates a defect in or an

encumbrance on the property owner's title, or renders the title

unmarketable; and, based on the policy language, whether the

First American policy covered plaintiff's claim. We answer both

questions in the negative and, therefore, affirm the order on

appeal.

I

To summarize, plaintiff bought foreclosed commercial

property at a sheriff's sale.1 The conditions of sale included a

provision that the property was being sold "subject to . . .

unpaid taxes or assessments." There were no delinquent taxes

outstanding at the time of the sale or on the effective date of

1 Princeton South's parent company, Rubenstein Properties Fund LP, was the successful bidder at the sheriff's sale and negotiated the title policy. Rubenstein created Princeton South as an entity to take title to the property. We will refer to Princeton South and Rubenstein, collectively, as plaintiff.

2 A-0850-12T3 the First American title policy. However, plaintiff contends

that municipal tax appeals covering several prior tax years,

which were pending at the time it bought the property,

constituted a title defect covered by the policy.2 Plaintiff

cites no cases from this State or from any other jurisdictions

that so hold.

On the other hand, defendant cites case law from other

jurisdictions that is both on point and persuasive. Defendant

further relies on language in the title policy, both in terms of

what is covered and what is excluded, that, read together,

convinces us that the policy does not insure against the

imposition of taxes assessed after the date the policy was

issued.

2 There is no dispute that before plaintiff closed on the property, its representatives knew that the tax assessment of the property was based on an unrealistically low value. Before closing on the property, plaintiff did not bring that information to First American's attention, ask the current owner or the municipal tax office about possible pending tax appeals, or order a tax search from the municipal tax office. See N.J.S.A. 54:5-12. While negotiating the terms of the title policy, but without disclosing its concerns about the low assessment, plaintiff asked First American to delete a policy exclusion for omitted or added assessments. First American refused to do so. Plaintiff claims it had no actual knowledge that there were pending tax appeals, until after the closing occurred. On the record before us, there is a material dispute of fact as to that issue. If plaintiff knew about the pending tax appeals before the closing, its claim would probably be barred by a policy exclusion for known risks the insured voluntarily undertook without disclosing those risks to First American.

3 A-0850-12T3 II

We review an order granting summary judgment de novo, using

the same legal standard employed by the trial court. Henry v.

N.J. Dep't of Human Servs., 204 N.J. 320, 330 (2010). Likewise,

we owe no deference to the trial court's legal interpretations,

including its construction of an insurance policy or other

contract. Ibid.

A title insurance policy is a "'contract that protects a

landowner against loss caused by defective title to the land.'"

N.J. Lawyers' Fund for Client Prot. v. Stewart Title Guar. Co.,

203 N.J. 208, 217 (2010) (quoting Shotmeyer v. N.J. Realty Title

Ins. Co., 195 N.J. 72, 82 (2008)). Title insurance protects a

buyer against the risk of defects that exist at the time the

policy is purchased, but not against the risk of defects that

may arise in the future. Shotmeyer, supra, 195 N.J. at 82. "In

that sense, title insurance covers 'a state of ownership at a

specific point in time.'" Ibid. (quoting 11 Couch on Insurance

§ 159:5 (3d ed. 1998)).

Like other types of insurance, a title insurance policy

should be "'liberally construed in favor of the insured and

strictly construed against the insurer.'" Ibid. (quoting

Sandler v. N.J. Realty Title Ins. Co., 36 N.J. 471, 478-79

(1962)). However, courts will enforce the title insurance

4 A-0850-12T3 policy as written and will not rewrite a more favorable policy

for the insured than the one purchased. See ibid.; Amidano v.

Donnelly, 260 N.J. Super. 148, 154 (App. Div. 1992), certif.

denied, 133 N.J. 435 (1993).

A.

Before focusing on the title policy at issue in this case,

it is helpful to consider the way annual property taxes are

assessed in New Jersey. First, the municipal tax assessor must

assess all property as of October 1 of the pretax year.

N.J.S.A. 54:4-23. After completing the preparation of the

municipal tax assessment list, the assessor files the list with

the County Board of Taxation (Board), which may examine, revise

and correct the proposed assessments. N.J.S.A. 54:4-35. The

annual taxes on a particular property are set by multiplying the

municipal tax rate – previously set by the Board – by the

property's assessed value. See East Orange v. Palmer, 47 N.J.

307, 317 (1966). The annual tax then "becomes due in four

installments on February 1, May 1, August 1 and November 1." Id.

at 318.

Once taxes are assessed, they give rise to a lien on the

property which continues unless they are paid. See N.J.S.A.

54:5-6 ("Taxes on lands shall be a continuous lien on the land

on which they are assessed . . . ." (emphasis added)). "A lien

5 A-0850-12T3 arises against the real estate on which the taxes are assessed

in the event of non-payment." S & R Assocs. v. Lynn Realty

Corp., 338 N.J. Super. 350, 360 (App. Div. 2001). In Princeton

Office Park v. Plymouth Park Tax Services, LLC, ___ N.J. ___,

___ (2014), the Court recently observed that N.J.S.A. 54:5-6

"confers on a municipality . . . 'a continuous lien on the

land'" for delinquent taxes, and provides that any subsequent

delinquent taxes are added to the lien. Id. at ___ (slip op. at

11) (quoting Simon v. Cronecker, 189 N.J. 304, 318 (2007)).

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