Rawlings v. Bank of America, N.A.

CourtDistrict Court, D. Maryland
DecidedDecember 18, 2024
Docket1:24-cv-01033
StatusUnknown

This text of Rawlings v. Bank of America, N.A. (Rawlings v. Bank of America, N.A.) is published on Counsel Stack Legal Research, covering District Court, D. Maryland primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rawlings v. Bank of America, N.A., (D. Md. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND ‘ * CHARLES RAWLINGS, * Plaintiff, v. □ | * Civil No. 24-1033-BAH BANK OF AMERICA, N.A., * Defendant. □ * * * * * * * * * * * * * * MEMORANDUM OPINION Plaintiff Charles Rawlings (“Plaintiff”) brought suit against Bank of America, N.A. (“Defendant”) alleging violations of the Fair Debt Collection Practices Act (“FDCPA”) as well as state law claims of negligence, fraud, and slander of title. ECF 1, at 1 (complaint)! Pending before the Court is Defendant’s motion to dismiss (the “Motion.”). ECF 9. All filings include memoranda of law and exhibits.2_ The Court has reviewed all relevant filings and finds that no hearing is necessary. See Loc. R. 105.6 (D. Md. 2023). Accordingly, for the reasons stated below, Defendant’s Motion is GRANTED. ,

Plaintiff filed an original complaint, ECF 1, on April 8, 2024. On May 13, 2024, Plaintiff filed both a motion for leave to amend the complaint, ECF 5, and a copy of the purportedly amended complaint, ECF 6. In its order dated June 21, 2024, the Court noted that both ECF 1 and ECF 6 appeared to be the same document and therefore indicated that Plaintiff could still file an amended complaint pursuant to Federal Rule of Civil Procedure 15(a)(1). ECF 12, at 1. The Court noted that Plaintiffs deadline to file the amended complaint was extended to July 9, 2024. Jd. Plaintiff received two further extensions, first. to July 23, 2024, ECF 14, at 1, and then to August 16, 2024, ECF 16, at 1. To date, the Court has not received an actual amended complaint from Plaintiff. The Court therefore treats the complaint docketed at ECF 1 as the operative complaint for this action, as it is substantively similar to the version docketed at ECF 6. > The Court references all filings by their respective ECF numbers and page numbers by the ECF- generated page numbers at the top of the page.

1. BACKGROUND ,

The substinee of Plaintiff's claims is difficult for the Court to ascertain as Plaintiff provides few facts sega the situation that gave rise to this action. As best the Court can tell, Plaintiff purports to bring bait under the FDCPA in connection with a foreclosure effectuated in 2020. ECF l,at3 9 14. Plaintiff notes that following receipt of “a demand for payment of an alleged debt obligation” from Defendant on May 20, 2020, his home was foreclosed on, and he was evicted on September 28 of 2020, Id. Plaintiff evidently contests this action firstly on the grounds that a judicial order awarding possession of the property to the lender was not filed until April 8, 2021 and secondly on he basis that the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) had suspended evictions through March 31, 2021. Id. . Plaintiff also evidently appears to argue that Defendant erroneously “claimed to be an agent of the bona fide bolder” of the mortgage obligation. ECF 1, at 3 16. In the event that Defendant does claim to be Ine holder of Plaintiff's mortgage obligation, Plaintiff says, he “demands strict proof of said sty” under the FDCPA, “specifically [] § 1692(g).” Jd. at 419. Plaintiff asserts “his proof . agency. to represent a principal with standing as evidenced in the court record to assert a claim mt capacity to prosecute said claim[.]” /d at 21. He avers that-he “has

. prosecuted this aqion in order to ascertain who the real party in interest is in the above matter.” Id. at J 23. Further, Plaintiff details his belief that there are several “inconsistencies, forgeries, and fraudulent oracties in the documents related to his mortgage” and states that, through his investigations, he he “uncovered a web of deceit that implicated major financial institutions and raised questions about the legality of millions of foreclosures.” ECF 1, at 4-5 {7 24-25. Asa result of these findings, he states that he has reason to believe “that Defendant subjected Plaintiff to a fraud and/or Lec scheme to collect monies not owed to Defendant,” and again demands | . 4

proof that he “entered into.a legal and binding contract with Defendant that would establish the alleged. debt” and that “Defendant is the singular and true holder in due course of said debt instrument.” Jd. at 7 | AI, 8 7 42. Plaintiff further demands additional proof related to the “chain of legal possession,” the “ownership of the alleged lien document and the alleged note,” and the “singular and exclusive claim” of Defendant upon the debt. /d. at 9 4 49, 10 50. Elsewhere in the complaint, in enumerating the counts he purports to bring, Plaintiff . provides some additional information about his view of the facts concerning the mortgage and foreclosure. Under Count 1, he alleges that Defendant improperly sent collection letters in 2008, 2016, and 2020 demanding payment on the debt without “provid[ing] evidence to show that Defendant was a bona fide holder of a debt instrument to which Plaintiff was liable.” ECF 1, at 10 § 53. He further asserts in Count 3 that Defendant “concealed the fact that the Loans were securitized as well as the terms of the securitization Agreements,” thereby concealing the character of the debt. fd. at 12 | 73. To summarize the Court’s understanding of the nature and circumstances of Plaintiff's claim, Plaintiff appears to be bringing a cause of action against Defendant based on his belief that Defendant erroneously and fraudulently asserted ownership of his mortgage obligation and thus improperly demanded payment of that debt. Plaintiff evidently argues by extension that these actions in some way caused the foreclosure and eviction, as he asserts that Defendant’s aim was to “deprive [Plaintiff] of their exclusive right, title, and interest in the Property, and to-obtain the Property for their own use by unlawful means.” ECF 1, at 17 7102. On this basis, he alleges that Defendant has engaged in violations of the FDCPA, negligence, fraud in the concealment, fraud in the inducement, and slander of title and he requests recission and declaratory relief. Jd. at □□□□ 19.

In _t Defendant avers that the property in question has already been the subject of a finalized foreclosure proceeding in Maryland state court and thus Plaintiff's claims are subject to dismissal “on the bases of res judicata and the Rooker-Feldman doctrine.” ECF 9-1, at 2. It notes that the flan proceeding was initiated on June 24, 2016 and ratified on January 28, 2020.3 Id (citing| ECF 9-3, 1-11 and ECF 9-4, at 1). Defendant further indicates that Plaintiff filed two separa appeals of the foreclosure action, and both were dismissed by the Appellate Court of Maryn on January 2, 2020 and June 18, 2020, respectively.* Jd. (citing ECF 9-5, □□ □ 11). Moreover, Defendant therefore argues that Plaintiffs complaint lacks sufficient factual allegations that Defendant “has committed any wrongdoing or that [Plaintiff] is entitled to relief,” □ and x iy claims should be dismissed. /d. at 3. Defendant raises these arguments in its motion to dismiss, ECF 9, filed on June 11, 2024. As detailed above in footnote 1, as a result of Plaintiffs health difficulties, the Court granted Plaintiff three ox(sion for filing either an amended complaint or a response in opposition to . Defendant’s nat for summary judgment. See ECFs 12, 14, 16. The final deadline was August 16, 2024. The Court has received no further communication from Plaintiff, save for a notice of change of address filed on October 11, 2024. See ECF 17. Il. LEGAL seaman Defendant has filed its motion to dismiss pursuant to Federal Rule of Civil Procedure 12(b)(6), which governs dismissals for failure to “state a claim upon which relief can be granted.”

3 Defendant notes|that the docket number for this case is No.

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Bluebook (online)
Rawlings v. Bank of America, N.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/rawlings-v-bank-of-america-na-mdd-2024.