RFB Prop., LLC v. Federal National Mortgage Association

CourtDistrict of Columbia Court of Appeals
DecidedOctober 27, 2022
Docket19-CV-527
StatusPublished

This text of RFB Prop., LLC v. Federal National Mortgage Association (RFB Prop., LLC v. Federal National Mortgage Association) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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RFB Prop., LLC v. Federal National Mortgage Association, (D.C. 2022).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 19-CV-0527

RFB PROPERTIES, LLC, APPELLANT,

v.

FEDERAL NATIONAL MORTGAGE ASSOCIATION, APPELLEE.

Appeal from the Superior Court of the District of Columbia (CAR-5383-18)

(Hon. Florence Y. Pan, Trial Judge)

(Argued December 10, 2020 Decided October 27, 2022)

Michael E. Brand for appellant.

Peter Duhig for appellee.

Before BLACKBURNE-RIGSBY, Chief Judge, and FERREN and THOMPSON, ∗ Senior Judges.

BLACKBURNE-RIGSBY, Chief Judge: Appellant RFB Properties, LLC (“RFB”)

challenges the trial court’s dismissal of its complaint to quiet title. RFB alleges that

the trial court erred when it determined that appellant lacked standing because its

∗ Judge Thompson was an Associate Judge of the court at the time of argument. She began her service as a Senior Judge on February 18, 2022. 2

corporate status had lapsed at the time it filed its complaint. We agree and reverse,

holding that RFB had standing to maintain its action to quiet title after its corporate

status was reinstated. RFB’s reinstatement related back to the date of its

administrative dissolution pursuant to D.C. Code § 29-106.03(d), and, as a result,

the actions RFB took during its period of administrative dissolution were validated

upon its corporate reinstatement. We therefore remand this case to the trial court to

adjudicate the merits of RFB’s quiet-title complaint.

I. Factual and Procedural History

Deborah Tang — a prior owner of condominium unit 233 at 3701 Connecticut

Avenue NW, Washington, D.C. (“the property”) — executed a note and deed of trust

on the property for $214,500 in favor of JP Morgan Chase Bank. JP Morgan

assigned its rights to the note and deed of trust to appellee Federal National Mortgage

Association (“FNMA”). Ms. Tang passed away shortly after, leaving the property

to Marie Canada in her will. Ms. Tang’s estate representative executed a quitclaim

deed on the property to Ms. Canada, who remained in privity with FNMA, the

mortgagee and holder of the deed of trust. After receiving the property, Ms. Canada

defaulted on her condominium association fees. 3

On August 21, 2014, the 3701 Connecticut Avenue Condominium Unit

Owner’s Association (“Condo Association”) recorded a notice of foreclosure sale

for assessments due on the property totaling $46,857.59 by Ms. Canada, pursuant to

D.C. Code § 42-1903.13 (2012 Repl.), which provided the Condo Association with

a super priority lien over other lien holders. 1 See Chase Plaza Condo. Ass’n v. JP

Morgan Chase Bank, N.A., 98 A.3d 166, 172 (D.C. 2014) (holding that “a

condominium association is permitted to foreclose on [its] six-month [super-

priority] lien and [to] distribute the proceeds from the foreclosure sale first to satisfy

[its super-priority] lien and then to satisfy any remaining liens in order of lien

priority”). Ms. Canada failed to cure by paying the assessment fees due. FNMA,

claiming it did not receive notice of the foreclosure sale as the mortgagee, therefore

likewise did not cure the defaulted assessment fees.

RFB, a company with an active corporate status at the time, purchased the

property for $10,500 at the Condo Association’s foreclosure sale, on September 23,

2014. RFB received the deed to the property approximately one month later, on

1 The 2014 condominium foreclosure sale was subject to the version of D.C. Code § 42-1903.13 contained in the 2001 edition of the Code. See D.C. Code § 42- 1903.13(a)(2) (establishing that a condominium association has a super priority lien). 4

October 22, 2014, and took possession of the property, but did not, at that time record

the deed. Before RFB recorded its deed, its corporate status was administratively

revoked on September 10, 2017, due to failure to timely file its two-year annual

report.

On December 23, 2016, more than two years after the condominium’s

foreclosure sale and RFB’s acquisition of the property, FNMA filed a complaint in

Superior Court against Ms. Canada for judicial foreclosure of the property following

her default under FNMA’s deed of trust. Ms. Canada failed to respond to the

complaint. On September 15, 2017, the trial court entered a default judgment in

favor of FNMA and entered a decree of sale authorizing foreclosure on the property.

On November 13, 2017, after learning FNMA had been awarded a default

judgment in its judicial foreclosure action, RFB recorded a copy of the deed from its

purchase of the property at the 2014 Condo Association foreclosure sale with the

Recorder of Deeds. Then two days later, on November 15, 2017, RFB emailed and

mailed FNMA a copy of its recorded deed.

FNMA conducted its foreclosure sale on November 16, 2017. During the sale,

in an attempt to demonstrate RFB’s rightful ownership of the property, a 5

representative from RFB interrupted the sale to verbally give notice of RFB’s title

with its recorded deed in hand. Nevertheless, the foreclosure sale proceeded and

FNMA purchased the property. The trial court then ratified the sale and approved

the accounting of the property’s sale.

On July 27, 2018, while still in possession of the property as a lessor, RFB

filed the underlying complaint in Superior Court to quiet title to the property, 2 asking

the trial court to issue an order concluding that RFB held title to the property and

that FNMA’s deed from the November 16, 2017, foreclosure was void. FNMA

moved to dismiss RFB’s complaint, alleging that RFB lacked standing and failed to

state a claim for relief. More specifically, FNMA argued that RFB lacked standing

to assert a claim to quiet title because it was not a corporate entity in good standing

at the time its complaint was filed. FNMA also asserted that RFB neglected to

protect its interest in the property against third parties when it failed to timely record

the deed after it purchased the property in September 2014.

2 In an affidavit submitted with its opposition to FNMA’s motion to dismiss RFB’s quiet-title action, RFB asserted that it had various tenants occupying the property through the date of FNMA’s judicial foreclosure sale in November of 2017. 6

In opposing dismissal, RFB noted that it had filed for reinstatement of its

corporate status, on September 25, 2018, and that reinstatement took effect the same

day. RFB further asserted that FNMA had inquiry notice of other interests in the

property based upon RFB’s “actual possession of the property” and based upon

recordation of the Condo Association’s “Notice of Lien” and “Notice of

Condominium Foreclosure Sale.” 3

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