Title Resources Guaranty Company v. Thomas Allen Francis

Michigan Court of Appeals·Decided August 18, 2026·No. 375599·Unpublished

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

TITLE RESOURCES GUARANTY COMPANY, UNPUBLISHED August 18, 2026

Plaintiff-Appellant, 10:52 AM

v No. 375599 St. Clair Circuit Court

THOMAS FRANCIS and MELISSA FRANCIS, LC No. 25-000365-CH

Defendants-Appellees.

Before: CAMERON, P.J., and MALDONADO and WALLACE, JJ.

PER CURIAM.

Plaintiff, Title Resources Guaranty Company, is the title insurance underwriter that insured title to a home that was being sold by the Curtisses in Fort Gratiot, Michigan. Liberty Title Agency (Liberty Title), a policy issuing agent of plaintiff, handled the closing of the sale. University Bank was supposed to issue a payoff statement for the mortgage on the property, but it mistakenly provided a payoff statement for the mortgage of defendants Thomas Francis and Melissa Francis, instead of the Curtiss mortgage. The Curtisses’ mortgage on their home was to be paid off and discharged as part of the transaction for its sale, but Liberty Title erroneously paid off the mortgage on the home of the defendants instead.

As detailed later in this opinion, defendants alerted Liberty Title about the issue, negotiated with Liberty Title and University Bank, and ultimately offered to give a private note or mortgage that would place defendants in the same position they occupied before their mortgage was paid off, but that offer was refused. Plaintiff, who had no relationship or interaction with defendants to that point, then placed a notice of lis pendens on defendants’ home and sued them for imposition of an equitable mortgage and unjust enrichment, despite the fact that plaintiff had not paid off the mortgage of its insureds. Summary disposition of that lawsuit was granted on defendants’ motion pursuant to MCR 2.116(C)(8). Only then did plaintiff incur the cost of paying off the Curtiss mortgage on the home that was sold, as was its contractual obligation as the title insurer for the purchaser, after which it moved for reconsideration of the order granting summary disposition to defendants. The trial court denied the motion for reconsideration and plaintiff filed this timely claim of appeal. We affirm.

I. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

In light of this being an appeal from a grant of summary disposition pursuant to MCR 2.116(C)(8), the underlying facts are not in dispute and are taken as alleged in plaintiff’s complaint.

Defendants own a home in Fort Gratiot, Michigan. In exchange for the purchase money loan defendants obtained from University Lending Group, LLC (University Lending), their home was encumbered by a purchase money mortgage given to Mortgage Electronic Registration Systems, Inc. (MERS), as University Lending Group’s nominee.

The Curtisses owned a home down the street from the defendants. Likewise in exchange for a purchase money loan the Curtisses obtained from University Lending, their home was also encumbered by a purchase money mortgage given to MERS, as University Lending’s nominee.

The Curtisses entered into a purchase agreement with an individual named Burkhardt for his purchase of their home. A policy issuing agent of plaintiff, Liberty Title Agency, handled the closing of the sale. Liberty Title contacted Midwest Loan Services, a division of University Bank, to obtain a payoff statement for the mortgage on the Curtisses’ home. Apparently erroneously, University Bank provided Liberty Title with a payoff statement for the mortgage on the Francis property. Liberty Title failed to notice that they had been provided a payoff statement for a different property on the same street as the Curtiss property, and then erroneously used this incorrect information to calculate the amount purportedly needed to pay off and discharge the Curtiss mortgage.

In connection with the closing on Burkhardt’s purchase of the Curtiss property, plaintiff issued Burkhardt a policy of title insurance guaranteeing that he was purchasing the Curtiss property free and clear of any encumbrances. Following the closing, Liberty Title wired the funds intended to pay off the Curtiss mortgage to University Bank, which funds were erroneously based on the information contained in the payoff statement for the Francis mortgage. University Bank, in turn, erroneously applied those funds to pay off the defendants’ mortgage, executed a discharge of that mortgage, and submitted that discharge for recording.

Thomas Francis thereafter discovered that a mistake had been made with regard to his and his wife’s mortgage being paid off and discharged, so he contacted Liberty Title to advise them of this issue. Additionally, the Curtiss mortgage was not discharged after the closing and continued to encumber the property despite Burkhardt having purchased it. Liberty Title endeavored to remediate the foregoing errors, but was informed by University Bank that the payoff funds erroneously applied to pay off the mortgage on the defendants’ property could not be returned and neither could the discharge of that mortgage be reversed.

Liberty Title and University Bank negotiated an arrangement between them whereby, at no cost or liability to defendants, University Bank would issue a new loan to defendants and Liberty Title would make a payment of its own funds to University Bank so that the terms of the new loan would allegedly be identical that of the mortgage on the Francis property that was erroneously paid off and discharged. Further, as part of this arrangement, plaintiff, Liberty Title, and University Bank agreed to provide a release to defendant. However, defendants would be required to submit a loan application, including providing financial disclosures and their credit

report. It was contemplated that the proceeds of the proposed new loan were to be used to pay off the Curtiss mortgage that now encumbered the title on the property Burkhardt purchased from the Curtisses.

Defendants responded to Liberty Title and University Bank’s overture by declining any arrangement whereby they would be obliged to apply for a new loan requiring them to provide credit reports and other financial disclosures that could in turn affect rates for loans that they would need to apply for that year and for the next several years. Defendants proposed an alternative arrangement whereby “[t]he loan proposed could be accomplished with a private note/mortgage, which do not require” them to “apply for a new loan or have the credit pull associated with it.” According to defendants, such an arrangement would place them in the exact position they occupied before Liberty Title and University Bank’s errors. Liberty Title and University Bank declined any arrangement that did not involve defendants applying for a new loan, requiring them to provide credit reports and other disclosures. There is no indication that plaintiff had any involvement in these discussions with defendants.

Plaintiff acknowledges that, under the policy of title insurance it issued to Burkhardt, guaranteeing that he was purchasing the Curtiss property free and clear of any encumbrances, it was contractually obligated to pay off the Curtisses’ mortgage encumbering Burkhardt’s title. However, rather than doing so, after defendants and Liberty Title and University Bank were unable to come to a mutually agreeable arrangement to return defendants to their original position with regard to their now paid off mortgage, plaintiff filed a notice of lis pendens1 on defendants’ home and sued them for imposition of an equitable mortgage and unjust enrichment.

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