Prunty v. Bank of America

37 Cal. App. 3d 430, 112 Cal. Rptr. 370, 1974 Cal. App. LEXIS 1144
CourtCalifornia Court of Appeal
DecidedFebruary 21, 1974
DocketCiv. 31687
StatusPublished
Cited by29 cases

This text of 37 Cal. App. 3d 430 (Prunty v. Bank of America) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Prunty v. Bank of America, 37 Cal. App. 3d 430, 112 Cal. Rptr. 370, 1974 Cal. App. LEXIS 1144 (Cal. Ct. App. 1974).

Opinion

*432 Opinion

RATTIGAN, Acting P. J.

The question presented on this appeal (apparently as a matter of first impression) is whether Code of Civil Procedure section 580b 1 bars a deficiency judgment, against a borrower and in favor of a lender, after judicial foreclosure and sale of real property under a deed of trust executed by the borrower to secure payment of a “construction loan” (1) which was used to finance construction of his personal residence on land already owned by him in fee, but (2) which was not used to finance his purchase of the land itself. We hold that the statute bars a deficiency judgment under the circumstances presented here.

Plaintiffs are the owners in fee of certain real property upon which they executed a deed of trust, in favor of defendant Bank of America as beneficiary, to secure payment of a construction loan made by the bank to them for the purpose of financing the erection of a residence on the property. The residence, was built and completed with the proceeds of the construction loan, but was demolished as the result of a natural disaster. In this action, thereafter commenced against the bank and the trustee under the deed of trust (defendant Continental Auxiliary Company), plaintiffs sought a declaratory judgment to the effect that Code of Civil Procedure section *433 580b barred the bank from recovering a deficiency judgment in the event of their default and a ludicial foreclosure and sale under the deed of trust. 2

After a nonjury trial, the court found in favor of plaintiffs and entered a declaratory judgment substantially as prayed. Defendants appeal from the declaratory judgment.

Facts

Including those just summarized, most of the material facts appear in the trial court’s findings. For this reason, and because they are undisputed, we quote the findings (with insignificant editorial changes, and with footnoted references to some evidence not specifically mentioned therein) as follows:

“Findings of Fact
“1. In 1964, plaintiffs purchased with their own funds certain unimproved real property generally known and described as 6163 Chelton Drive, Oakland, California, intending to build their own home thereon. 2. In 1965, while the property was still unimproved, plaintiffs applied to defendant Bank of America for a loan in the sum of $40,000. 3. On June 23, 1965, defendant Bank of America loaned $40,000 to plaintiffs[ 3 ] and plaintiffs gave defendant their note in the sum of $40,000 and a deed of trust against said real property. 4. Said note provided that said loan would be repaid in equal monthly installments, including principal and interest, over a 25-year period.
*434 “5. The forms of the note and deed of trust used in the transaction by. the [defendant] Bank of America were the same as the forms it would use for a loan to an individual to purchase real property with a home already constructed on it. 6. Said deed of trust was recorded on June 25, 1965, in the official records of Alameda County . . .
“7. It was intended both by plaintiffs and defendants that the repayment of said loan would be secured by said deed of trust which would cover not only the land but also a dwelling to be constructed thereon. 8. At the time of the application for said loan and at the time of the execution and recording of said deed of trust, plaintiffs intended to use the proceeds of said loan to construct a single family residential dwelling on the property, which they themselves would occupy, and defendant Bank of America was aware and intended that the proceeds of said loan would be so used.
“9. All the proceeds of said loan were used by plaintiffs to pay the purchase price of labor and materials which were used in constructing a single family residence on the property. 10. Defendant Bank of America would not have made said loan had not the entire proceeds of said loan been used to pay the purchase price of labor and materials used to construct the residence on said land. 11. Defendant Bank of America looked primarily to the land and to the building thereon as security for its loan.
“12. Said land, without the improvements [constructed] thereon, had a value of $7,500. 13. After the construction of said improvements, said land had a fair market value of $96,000. 14. Upon completion of the construction of the dwelling, it was occupied by plaintiffs and used by them as their place of residence. 15. In April, 1967, a major landslide occurred in the area of the residence. As a result of the damage done to the residence and to the real property itself, the residence was torn down and demolished.
“16. Defendant Bank of America required that plaintiffs have a policy of insurance on the land and improvements with a lender’s loss payable endorsement.[ 4 ] 17. Plaintiffs obtained said policy of insurance but it did not cover them or defendant Bank of America against the risk of a landslide. 18. No insurance which would cover said risk was available to the parties. 19. To the extent of the unpaid balance of its loan to plaintiffs, *435 . . . [defendant bank] ... is subrogated to plaintiffs’ claims against any other party for damages suffered by reason of the destruction of their residence.” 5

In the declaratory judgment entered pursuant to the above-quoted findings, the trial court ordered that defendant bank was not entitled to recover a deficiency judgment from, plaintiffs. The court unmistakably determined that a deficiency judgment was barred, under the facts as found, by the provisions of section 580b. 6 Upon examination of the facts in light of the language of the statute as amended in 1963 (see fn. 1, ante), we agree: for the reasons next stated, we affirm the declaratory judgment.

On their appeal from the declaratory judgment, defendants first contend that section 580b does not bar a deficiency judgment in this case because the deed of trust given by plaintiffs was not a “purchase money” instrument “within the meaning” of the statute. (See fn. 1, ante.) The contention rests upon the premises (1) that section 580b operates to bar a deficiency judgment after the sale of real property under a “purchase money” mortgage or trust deed only, and (2) that plaintiffs’ trust deed was not a “purchase money” instrument because it was given to secure payment of a construction loan whose proceeds financed the residential improvement of their property but not its “purchase.”

Defendants’ first premise is undeniably correct: section 580b has consistently been interpreted as barring “any deficiency judgment after sale under a purchase money mortgage or trust deed” only. (Roseleaf Corp. v. Chierighino (1963) 59 Cal.2d 35, 41 [27 Cal.Rptr.

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Cite This Page — Counsel Stack

Bluebook (online)
37 Cal. App. 3d 430, 112 Cal. Rptr. 370, 1974 Cal. App. LEXIS 1144, Counsel Stack Legal Research, https://law.counselstack.com/opinion/prunty-v-bank-of-america-calctapp-1974.