Staab v. Wells Fargo Bank, N.A.

CourtDistrict of Columbia Court of Appeals
DecidedDecember 12, 2024
Docket23-CV-0492 & 23-CV-0669
StatusPublished

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Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

Nos. 23-CV-0492 & 23-CV-0669

SARAH STAAB, APPELLANT,

V.

WELLS FARGO BANK, N.A., APPELLEE.

Appeals from the Superior Court of the District of Columbia (2015-CA-004100-R(RP))

(Hon. Fern Flanagan Saddler & Hon. Maurice A. Ross, Motions Judges)

(Argued June 6, 2024 Decided December 12, 2024)

Robert C. Gill for appellant.

Daniel Z. Herbst for appellee.

Michael A.F. Johnson filed a brief on behalf of Federal Housing Finance Agency, as amicus curiae.

Before EASTERLY, MCLEESE, and DEAHL, Associate Judges.

EASTERLY, Associate Judge: Sarah Staab purchased a condominium unit at a

foreclosure sale conducted by the condominium association to recover unpaid fees.

In this appeal, she challenges two Superior Court orders ruling, inter alia, that the 2

sale of the unit to Ms. Staab was barred by the Federal Foreclosure Bar, 12 U.S.C.

§ 4617(j)(3), and thus is void, and granting summary judgment to Wells Fargo Bank,

N.A. (“Wells Fargo”) on its claims for judicial foreclosure, declaratory judgment,

and quiet title. Ms. Staab does not contest that, at the time she purchased it, the

property was encumbered by a deed of trust owned by the Federal Housing Finance

Agency (“FHFA”) and the Federal National Mortgage Association (“Fannie Mae”)

and serviced by Wells Fargo. Nor does she dispute the application of the Federal

Foreclosure Bar. Instead, Ms. Staab makes three procedural arguments. She asserts

the Superior Court (1) applied the incorrect statute of limitations to determine that

Wells Fargo’s amended complaint, which raised for the first time facts and claims

related to the Federal Foreclosure Bar, was not time barred; (2) abused its discretion

by granting Wells Fargo leave to amend its complaint, years after it first filed its

action for judicial foreclosure; and (3) abused its discretion by not joining the

condominium association as an indispensable party to the action. We are

unpersuaded.

First, Wells Fargo’s initial action for judicial foreclosure was indisputably

timely, having been brought within three years of the foreclosure sale at which

Ms. Staab purchased the property. The additional facts and arguments Wells Fargo

subsequently raised—though incorporated in an amended complaint—were in direct

response to an affirmative defense pled by Ms. Staab, and thus they were not 3

required to be a part of the bank’s initial complaint. Further, the relief ultimately

granted was within the court’s equity powers to award on the judicial foreclosure

claim alone. Second, we conclude that, whether or not the Superior Court abused

its discretion in granting Wells Fargo leave to amend its complaint, any error would

be harmless because Wells Fargo could permissibly have raised the same arguments

when it sought summary judgment on its judicial foreclosure claim. Third, we

conclude that the Superior Court did not abuse its discretion in determining that the

condominium association was not an essential party under Super. Ct. Civ.

R. 19(a)(1). Accordingly, we affirm the Superior Court’s judgment.

I. Background

The following facts are not in dispute. In 2006, William J. Sutcliffe borrowed

$193,000 from Wells Fargo to purchase a condominium unit on Pennsylvania

Avenue, NW. Mr. Sutcliffe secured the loan by executing a promissory note and a

deed of trust on the property in Wells Fargo’s favor. Shortly after, Wells Fargo

transferred ownership of the promissory note and deed of trust to Fannie Mae, 1 but

continued to service the mortgage on Fannie Mae’s behalf.

1 Ms. Staab notes that the transfer of the mortgage from Wells Fargo to Fannie Mae is not a matter of public record but does not appear to dispute that the transfer occurred. 4

In 2008, Congress enacted the Housing and Economic Recovery Act of 2008

(“HERA”), Pub. L. No. 110-289, 122 Stat. 2654 (2008) (codified in scattered

sections of 10 U.S.C., 12 U.S.C., 15 U.S.C., 26 U.S.C., 31 U.S.C., 37 U.S.C., 38

U.S.C., and 42 U.S.C.), which authorized the FHFA to place Fannie Mae under a

conservatorship, see 12 U.S.C. § 4617(a)(2). As Fannie Mae’s conservator, the

FHFA “immediately succeed[ed]” to all of Fannie Mae’s “rights, titles, powers, and

privileges.” 12 U.S.C. § 4617(b)(2)(A). HERA also created what is known as the

“Federal Foreclosure Bar,” which prohibits FHFA property from being “subject

to . . . foreclosure[] or sale without the consent of the Agency.” Id. at § 4617(j)(3).

In 2011, Mr. Sutcliffe defaulted on his mortgage and fell behind on his

condominium assessments. The Residential Association of the Pennsylvania

(“Residential Association”)—the condominium association for the property—

recorded two liens against Mr. Sutcliffe and initiated a foreclosure action against the

property under D.C. Code § 42-1903.13. In 2013, it sold the property to Ms. Staab

for $15,000.

In 2015, Wells Fargo filed a judicial foreclosure action in D.C. Superior Court

under D.C. Code § 42-816 against Mr. Sutcliffe and Ms. Staab. The complaint did

not mention that Fannie Mae now owned the deed of trust. The following month,

Ms. Staab filed an answer that raised several affirmative defenses, including that 5

“[a]ny interest [Wells Fargo] may have had in the [p]roperty was extinguished by

the sale of the [p]roperty to [Ms.] Staab.” 2 The case was delayed for almost four

years, during which time Wells Fargo unsuccessfully attempted to serve

Mr. Sutcliffe (and eventually received permission to effect service via publication).

In 2019, Wells Fargo moved for leave to amend its complaint to add the Residential

Association as a defendant and to add new facts—including that Fannie Mae owned

the mortgage—and new claims—including a claim for declaratory judgment that the

Residential Association’s foreclosure and sale of the property to Ms. Staab without

the FHFA’s consent was void under the Federal Foreclosure Bar, and a claim to quiet

title. The Superior Court (Hon. Fern Flanagan Saddler) granted Wells Fargo leave

to amend over Ms. Staab’s objection. Wells Fargo then agreed to voluntarily dismiss

the Residential Association from the action.

After both parties filed for summary judgment, the Superior Court

(Hon. Maurice Ross) granted summary judgment for Wells Fargo, determining that

Wells Fargo’s claims were timely, the Residential Association’s foreclosure and sale

of the property to Ms. Staab were void under the Federal Foreclosure Bar, and the

2 Ms. Staab presumably was relying on this court’s holding in Chase Plaza Condominium Association, Inc. v. JPMorgan Chase Bank, N.A., 98 A.3d 166 (D.C.

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