South Shore Bank v. Stewart Title Guaranty Co.

688 F. Supp. 803, 28 ERC (BNA) 1391, 1988 U.S. Dist. LEXIS 6782, 1988 WL 72124
CourtDistrict Court, D. Massachusetts
DecidedJune 16, 1988
DocketCiv. A. 87-2173-Z
StatusPublished
Cited by3 cases

This text of 688 F. Supp. 803 (South Shore Bank v. Stewart Title Guaranty Co.) is published on Counsel Stack Legal Research, covering District Court, D. Massachusetts primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
South Shore Bank v. Stewart Title Guaranty Co., 688 F. Supp. 803, 28 ERC (BNA) 1391, 1988 U.S. Dist. LEXIS 6782, 1988 WL 72124 (D. Mass. 1988).

Opinion

MEMORANDUM OF DECISION

ZOBEL, District Judge.

Plaintiff, South Shore Bank (“South Shore”), seeks a declaration that defendant, Stewart Title Guaranty Company (“Stewart”), is liable for the expense of removal, clean-up, and monitoring of hazardous waste on property insured under a title insurance policy issued by Stewart in favor of South Shore. Plaintiff also seeks damages for breach of contract together with costs and attorneys’ fees. Defendant has moved for summary judgment and for sanctions under Rule 11, Federal Rules of Civil Procedure. 1

The following facts are not in dispute. On July 12, 1985, South Shore loaned J & B Realty Partnership (“J & B”) $2,800,000, the security for which was a mortgage on certain property located in Bridgeport, Connecticut (“the Property”). On July 22, 1985, Stewart issued a policy of title insurance on the Property to South Shore, the mortgagee. An endorsement to the policy provides in pertinent part: “The Company insures against loss or damage sustained by the insured by reason of a lien which attaches to the insured premises pursuant to section 22a-452a of the Connecticut General Statutes as a result of conditions exist ing on or at the insured premises as of the date of the policy if such lien claims priority over the lien of the insured mortgage.” Under the cited statute, the commissioner of environmental protection (“the commissioner”) may file a lien on property if he cleaned it of hazardous waste with state funds to secure reimbursement thereof.

During 1986, J & B defaulted on its loan payments. Thereafter, an environmental assessment of the site determined the presence of hazardous waste on the Property. When South Shore was advised thereof, it notified Stewart that it expected to claim against the policy following foreclosure. On July 24, 1987, a foreclosure sale was held and South Shore was successful in its bid for the Property.

Defendant’s motion for summary judgment is premised on the ground, inter alia, that the endorsement is inapplicable because no lien has been filed pursuant to § 22a-452a and insurance coverage is not triggered by the possibility that such a lien may be filed in the future.

Summary judgment is appropriate only if the pleadings, depositions, answers to interrogatories, and admissions on file, together with affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law. Fed.R.Civ.P. 56(c). See also, Bratt v. International Business Machines Corp., 785 F.2d 352, 359 (1st Cir.1986). To oppose such a motion successfully, a plaintiff “must set forth specific facts showing that there is a genuine issue for trial.” Fed.R.Civ.P. 56(e).

Plaintiff argues that a genuine issue of material fact exists as to whether foreclosure by it extinguishes insurance coverage. However, even if plaintiff is correct that the policy and the endorsement remain in force after foreclosure on the Property, plaintiff has failed to allege the existence of a commissioner’s lien to warrant application of Conn.Gen.Stat. § 22a-452a to this case. 2

*805 As noted, the endorsement provides coverage for loss or damages “sustained by the insured by reason of a lien which attaches to the insured premises pursuant to section 22a-452a 3 of the Connecticut General Statutes....” Under Connecticut law, a lien is “[a] hold or claim which one person has upon the property of another as a security for some debt or charge.” Interstate Fur Mfg. Co. v. Redevelopment Agency, 154 Conn. 600, 604, 227 A.2d 425, 426 (1967). The lien described in § 22a-452a arises when state funds have been expended to contain, remove or mitigate the effects of hazardous waste. The statute delineates the procedural requirements necessary to effectuate this type of lien. First, a certificate of lien must be filed in the town where the real estate is located; and second, the commissioner must mail a copy of the certificate to all persons holding an interest in the real estate as notification of the priority of the commissioner’s lien.

First, plaintiff has failed to allege the existence of a commissioner’s lien. In fact, plaintiff does not controvert the affidavit of Robert Anderson, Stewart’s New England manager, to the effect that no lien on the Property has been filed in the land records of Bridgeport, Connecticut, pursuant to § 22a-452a, indeed, that no lien has arisen as no amounts have been paid by the commissioner in this regard. Hence, § 22a-452a is inapposite here.

Second, as a matter of law, the possibility that the commissioner may file a lien does not trigger insurance coverage under the endorsement. In Chicago Title Insurance Co. v. Kumar, 24 Mass.App.Ct. 53, 506 N.E.2d 154 (1987), a landowner alleged that release of hazardous material was a defect in title within the meaning of his title insurance policy and that the Commonwealth’s power to impose a future lien under Mass.Gen.L. ch. 21E, § 13 (1986) rendered his title unmarketable. The Massachusetts Appeals Court, however, found that the possibility of a future lien did not give the landowner a cause of action.

The mere possibility that the Commonwealth may attach a future lien under G.L. c. 21E, § 13, as a result of the release of hazardous material (existing but unknown at the time a title insurance policy is issued) when the Commonwealth has neither expended moneys on the property requiring reimbursement nor recorded the necessary statement of claim, is insufficient to create a “defect in or lien or encumbrance on ... title.”

Kumar, 24 Mass.App.Ct. at 56, 506 N.E.2d at 156.

Plaintiff maintains that the policy behind the Connecticut statute is to provide an immediate response to the existence of hazardous waste materials which will be frustrated if the property owner waits for a lien to be filed by the commissioner. Inclusion in the policy of § 22a-452a has a different purpose, however. The reference to the statute in the endorsement is not to ensure an immediate response to environmental pollution but rather to protect the *806 insured from a challenge to its title by reason of a commissioner’s lien that has priority over South Shore’s legal rights in the Property. See Kumar, 24 Mass.App.Ct. at 57, 506 N.E.2d at 157 (title marketability relates to defects affecting legally recognized rights and incidents of ownership). Plaintiff has neither alleged nor offered any facts to show a defect in title.

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Related

Cargill v. Gilmore
1 Mass. L. Rptr. 167 (Massachusetts Superior Court, 1993)
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South Shore Bank v. Stewart Title Company
867 F.2d 607 (First Circuit, 1988)

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Bluebook (online)
688 F. Supp. 803, 28 ERC (BNA) 1391, 1988 U.S. Dist. LEXIS 6782, 1988 WL 72124, Counsel Stack Legal Research, https://law.counselstack.com/opinion/south-shore-bank-v-stewart-title-guaranty-co-mad-1988.