Samuel Evans and Sandra Evans v. MC & J Investments, LLC

CourtMississippi Supreme Court
DecidedJanuary 25, 2024
Docket2022-CA-01248-SCT
StatusPublished

This text of Samuel Evans and Sandra Evans v. MC & J Investments, LLC (Samuel Evans and Sandra Evans v. MC & J Investments, LLC) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Samuel Evans and Sandra Evans v. MC & J Investments, LLC, (Mich. 2024).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2022-CA-01248-SCT

SAMUEL EVANS AND SANDRA EVANS

v.

MC&J INVESTMENTS, LLC

DATE OF JUDGMENT: 11/18/2022 TRIAL JUDGE: HON. RODNEY PURVIS FAVER TRIAL COURT ATTORNEYS: JAY HOWARD HURDLE BENNIE L. JONES, JR. JOSEPH N. STUDDARD H. SCOTT ROSS STEVIE FARRAR RUSHING CHRISTINA M. SEANOR MARK A. CLIETT CHARLES FRANK FAIR BARBOUR COURT FROM WHICH APPEALED: CLAY COUNTY CHANCERY COURT ATTORNEY FOR APPELLANTS: BENNIE L. JONES, JR. ATTORNEY FOR APPELLEE: MARK A. CLIETT NATURE OF THE CASE: CIVIL - REAL PROPERTY DISPOSITION: AFFIRMED - 01/25/2024 MOTION FOR REHEARING FILED:

BEFORE KITCHENS, P.J., COLEMAN AND GRIFFIS, JJ.

GRIFFIS, JUSTICE, FOR THE COURT:

¶1. Samuel Evans and Sandra Evans appeal the trial court’s refusal to set aside a

foreclosure sale. We find no error and affirm.

FACTS AND PROCEDURAL HISTORY

¶2. On December 19, 2003, Samuel and his wife Sandra executed a deed of trust securing repayment of $40,800 for real property1 located in Clay County. The deed of trust granted

a security interest in the property to the original lender, United Financial Mortgage

Corporation, and was later assigned to U.S. Bank.

¶3. Samuel and Sandra defaulted on their payments, and foreclosure proceedings were

initiated. Samuel and Sandra were advised that the foreclosure sale was scheduled for

January 4, 2017.

¶4. Samuel and Sandra contacted and entered into discussions with Bank of America to

bring their payment obligations current in order to avoid foreclosure. On December 22,

2016, Bank of America sent Samuel and Sandra a document entitled “Reinstatement

Calculation” in which Bank of America represented the reinstatement amount necessary to

reinstate the debt secured by the deed of trust. The reinstatement calculation instructed

Samuel and Sandra to send certified funds or money order to Bank of America in the amount

of $9,511.13. The reinstatement calculation noted that the reinstatement amount was “good

through” January 3, 2017.

¶5. According to Samuel, a Bank of America employee advised him that as long as Bank

of America received the reinstatement amount before the foreclosure sale, the sale would not

occur. Samuel sent the reinstatement payment by FedEx on January 3 for an early delivery

on January 4, before the scheduled foreclosure sale. Samuel and Sandra assumed that they

had brought their debt current and that the foreclosure sale would not go forward. They later

learned, however, that despite representations by Bank of America, the foreclosure sale had

1 The real property consists of three acres of land and a house on that land.

2 occurred. Neither Samuel nor Sandra attended the foreclosure sale.

¶6. The property at issue was purchased at the foreclosure sale by MC&J Investments,

LLC, for $15,834.83. Julious McClinton, a real estate investor who buys properties in

foreclosure, is the managing member of MC&J Investments. After the foreclosure sale, a

substituted trustee’s deed was issued to MC&J. The deed was later recorded on January 23,

2017, in the land records of Clay County.

¶7. On February 23, 2018, Samuel and Sandra filed a complaint in Clay County Chancery

Court against U.S. Bank, Bank of America, Underwood Law Firm, PLLC,2 and MC&J

Investments. In their complaint, Samuel and Sandra alleged: (1) Bank of America

intentionally and/or negligently misrepresented that Samuel and Sandra could make their

reinstatement payment prior to the start of the scheduled foreclosure in order to avoid

foreclosure, (2) Defendants failed to follow Mississippi law and wrongfully proceeded with

the foreclosure sale, (3) Defendants sold the property at foreclosure for legally inadequate

consideration, making the foreclosure sale void, and (4) Defendants never had the legal

authority to foreclose on the property. Samuel and Sandra sought “[t]o set aside the

foreclosure sale as void and to vest title to the [r]eal [p]roperty as it was immediately before

the wrongful sale[.]” They further sought compensatory, general, special, consequential, and

punitive damages as well as reasonable costs and attorneys’ fees.

¶8. On December 6, 2020, Samuel and Sandra voluntarily dismissed without prejudice

their claims against U.S. Bank, Bank of America, and Underwood Law Firm, PLLC, for their

2 Underwood Law Firm, PLLC, conducted the foreclosure sale.

3 inability to serve those Defendants, leaving MC&J Investments as the only remaining

Defendant.

¶9. MC&J Investments filed its answer to Samuel and Sandra’s complaint and also filed

a counterclaim for defamation, intentional infliction of emotional distress, violation of the

Litigation Accountability Act, and negligence. Samuel and Sandra filed their response to

MC&J Investments’ counterclaim.

¶10. Trial was held on June 23, 2022. At trial, Samuel testified regarding an alleged oral

agreement with McClinton in which McClinton agreed to buy the property at the foreclosure

sale and then sell it back to Samuel. Samuel acknowledged that the alleged agreement was

not reduced to writing.

¶11. The trial court entered an “Opinion and Final Judgment on Plaintiffs’ Complaint

against MC&J Investments, LLC and MC&J’s Counterclaim against Plaintiffs” on November

18, 2022, denying Samuel and Sandra’s claims against MC&J Investments and MC&J

Investments’ counterclaim against Samuel and Sandra. Specifically, the trial court found as

follows: (1) the bid price paid by MC&J Investments did not shock the conscience of the

court, (2) no writing was produced to support Samuel’s claim that McClinton promised to

sell him back the property, and (3) MC&J Investments failed to establish any harm or

damages.

¶12. Samuel and Sandra timely appealed the trial court’s denial of their claims against

MC&J Investments.3 On appeal, they argue: (1) the trial court erred by finding the statute

3 MC&J Investments did not appeal the trial court’s denial of its counterclaim.

4 of frauds prevented the enforcement of a promise to sell back the property to Samuel and

Sandra, and (2) the trial court erred by finding the price paid at the foreclosure sale was not

so inadequate as to shock the conscience and by failing to set aside the foreclosure sale.

DISCUSSION

I. Whether the trial court erred by finding the statute of frauds prevented the enforcement of a promise to sell back the property to Samuel and Sandra.

¶13. “Our statute of frauds statute, Mississippi Code Annotated section 15-3-1 (Rev. 2003),

lists the types of contracts that must be in writing. Contracts for the sale of lands, tenements,

or hereditaments are included.” Thompson v. First Am. Nat’l Bank, 19 So. 3d 784, 787

(Miss. Ct. App. 2009) (citing Miss. Code Ann. § 15-3-1(c)). Here, the alleged oral

agreement between Samuel and McClinton was for the sale of property consisting of three

acres of land and a house located on that land. Because the agreement involved land, it was

required to be in writing. Miss. Code Ann. § 15-3-1(c) (Rev. 2019). It is undisputed that the

agreement was not in writing. Accordingly, it is barred under the statute of frauds. Id.

¶14.

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Samuel Evans and Sandra Evans v. MC & J Investments, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/samuel-evans-and-sandra-evans-v-mc-j-investments-llc-miss-2024.