Ruben Garcia, Jr. v. Title Check, LLC

CourtCourt of Appeals for the Sixth Circuit
DecidedApril 5, 2023
Docket22-1578
StatusUnpublished

This text of Ruben Garcia, Jr. v. Title Check, LLC (Ruben Garcia, Jr. v. Title Check, LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ruben Garcia, Jr. v. Title Check, LLC, (6th Cir. 2023).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 23a0159n.06

Nos. 22-1574/1578 FILED UNITED STATES COURT OF APPEALS Apr 05, 2023 FOR THE SIXTH CIRCUIT DEBORAH S. HUNT, Clerk

RUBEN GARCIA, JR., and a class of property ) ) buyers similarly situated (22-1574), ) Plaintiff-Appellant, ) ) PHILIP LEE ELLISON, MATTHEW EDWIN ) ON APPEAL FROM THE UNITED GRONDA (22-1578), ) STATES DISTRICT COURT FOR Interested Parties-Appellants, ) THE WESTERN DISTRICT OF ) MICHIGAN v. ) ) OPINION TITLE CHECK, LLC, ) ) Defendant-Appellee. ) )

Before: GILMAN, KETHLEDGE, and MURPHY, Circuit Judges.

PER CURIAM. Ruben Garcia, Jr., and his attorneys, Philip Lee Ellison and Matthew

Edwin Gronda, appeal the district court’s order imposing sanctions against counsel for bringing

and litigating a frivolous lawsuit against Title Check, LLC. Because the district court did not

abuse its discretion, we affirm its sanctions order.

Garcia, through Ellison and Gronda as counsel, sued Title Check over fees that it charged

for running tax-foreclosure auctions on behalf of Michigan governmental entities. In 2018, Garcia

bought real estate in Bay County at a foreclosure auction. His winning bid was $11,500, but as

described in the auction rules, the full purchase price included Title Check’s additional ten-percent

buyer’s fee of $1,150. Garcia alleged that this fee violated Michigan’s General Property Tax Act, Nos. 22-1574/1578, Garcia, et al. v. Title Check, LLC

which provided that properties must be offered for auction at a “minimum bid” that “shall include”

all outstanding taxes, interest, penalties, and fees due on the property and all expenses of preparing

for and administering the auction. Mich. Comp. Laws § 211.78m(16)(a) (2018). Garcia claimed

that the statute authorized only those items to be included in the minimum bid, making the buyer’s

fee illegal. He brought claims against Title Check for Hobbs Act extortion and wire fraud under

the Racketeer Influenced and Corrupt Organizations Act (“RICO”) and for unjust enrichment

under Michigan law. He sought damages and injunctive relief and proposed to represent a class

of similarly situated buyers.

The district court granted Title Check’s motion to dismiss Garcia’s amended complaint,

holding that the Michigan statute’s “shall include” language merely required the minimum bid to

consist of certain items to ensure that the governmental entity at least recouped the taxes owed

plus all associated costs, but that it did not prohibit Title Check’s buyer’s fee. The district court

held that, because the fee was not improper, Garcia had not alleged facts that could support his

Hobbs Act extortion and wire-fraud claims under RICO, and because a contract governed his

purchase at auction and he knew the terms and received what he bargained for, he did not

sufficiently plead an unjust-enrichment claim.

Garcia, still through attorneys Ellison and Gronda, appealed. We affirmed the district

court’s decision, holding that the statute’s language delineating what the minimum bid “shall

include” was not exhaustive and thus did not prohibit Title Check’s buyer’s fee. Garcia petitioned

for rehearing en banc, which was denied.

Title Check then moved for sanctions in the district court against Ellison and Gronda under

28 U.S.C. § 1927 and the court’s inherent authority, arguing that Garcia’s case was frivolous and

their persistence in litigating it needlessly cost the defendant company thousands of dollars in legal Nos. 22-1574/1578, Garcia, et al. v. Title Check, LLC

fees. Title Check reasoned that counsel’s legal theory about the statutory language was baseless

and, even if it were not, that the RICO and unjust-enrichment claims were patently meritless. The

company also argued that counsel knew that the case lacked a good-faith basis because opposing

counsel explained as much by letter at the start of the litigation. Title Check further asserted that

Garcia’s attorneys brought the case for the improper purpose of obtaining discovery that counsel

could use to file cases about a separate issue with foreclosure auctions that had spawned a flood

of litigation in Michigan courts. See Rafaeli, LLC v. Oakland County, 952 N.W.2d 434, 440 (Mich.

2020). In response, Ellison and Gronda argued that the case was not brought in bad faith and that

they had advanced a plausible theory of statutory interpretation about a novel question of law.

The district court granted Title Check’s motion and ordered Ellison and Gronda to pay the

attorney’s fees and costs that the company incurred in defending the case: $73,752.45. The court,

relying solely on § 1927, determined that Garcia’s complaint was frivolous and that, because his

attorneys should have known that the claims were frivolous, they ‘“unreasonably and vexatiously’

multiplied the proceedings.” The court thus concluded that § 1927 sanctions were warranted.

Garcia appealed, as did Ellison and Gronda, and their cases were consolidated. We denied

their motion to stay the sanctions order pending appeal without bond, noting that “[c]ounsel made

no efforts to engage with [Federal Rule of Civil Procedure] 62(b),” which provides that a bond or

other security is required to obtain a stay. On appeal, they argue that the district court erred in

three ways: (1) by imposing against Garcia sanctions that are limited to attorneys; (2) by awarding

sanctions for the full amount of work performed by Title Check’s counsel instead of the amount

that related to the unnecessary filings; and (3) by levying sanctions based on a misunderstanding

of Michigan precedent, even though the legal issue was a matter of first impression. Nos. 22-1574/1578, Garcia, et al. v. Title Check, LLC

Under § 1927, a court can order an “attorney . . . who so multiplies the proceedings in any

case unreasonably and vexatiously . . . to satisfy personally the excess costs, expenses, and

attorneys’ fees reasonably incurred because of such conduct.” 28 U.S.C. § 1927. Sanctions are

warranted “when an attorney objectively ‘falls short of the obligations owed by a member of the

bar to the court.’ While subjective bad faith is not required, the attorney in question must at least

knowingly disregard the risk of abusing the judicial system, not be merely negligent.” Kidis

v. Reid, 976 F.3d 708, 723 (6th Cir. 2020) (quoting Carter v. Hickory Healthcare Inc., 905 F.3d

963, 968 (6th Cir. 2018)). We review under the abuse-of-discretion standard a district court’s

award of sanctions under § 1927. United States v. Llanez-Garcia, 735 F.3d 483, 491 (6th Cir.

2013).

The district court did not abuse its discretion by imposing sanctions against Ellison and

Gronda. Counsel continued to press frivolous causes of action based on an implausible parsing of

the statutory language. Their argument that Title Check engaged in extortion and wire fraud under

RICO by charging a buyer’s premium to the auction price was unreasonable on its face. And their

claim for unjust enrichment was meritless given that a contract governed the auction, which, under

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