Titshaw v. Northeast Georgia Bank

697 S.E.2d 837, 304 Ga. App. 712, 2010 Fulton County D. Rep. 2217, 2010 Ga. App. LEXIS 604
CourtCourt of Appeals of Georgia
DecidedJune 30, 2010
DocketA10A0533, A10A0550
StatusPublished
Cited by6 cases

This text of 697 S.E.2d 837 (Titshaw v. Northeast Georgia Bank) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Titshaw v. Northeast Georgia Bank, 697 S.E.2d 837, 304 Ga. App. 712, 2010 Fulton County D. Rep. 2217, 2010 Ga. App. LEXIS 604 (Ga. Ct. App. 2010).

Opinion

PHIPPS, Presiding Judge.

Chuck Titshaw, David Healan, and Jackson County Investment Ventures, LLC appeal from two superior court orders confirming foreclosure sales of real property. In both cases, the appellants contend that Northeast Georgia Bank, the entity that obtained the confirmations, was not the proper party to do so. We find no merit in this contention. In Case No. A10A0533, the appellants contend additionally that the superior court confirmed the foreclosure sale underlying that case without a sufficient evidentiary basis for doing so. We agree. Therefore, the judgment in Case No. A10A0533 is reversed, and the judgment in Case No. A10A0550 is affirmed.

In October 2007, Jackson County Investment Ventures borrowed money from Freedom Bank of Georgia. In connection therewith: (i) promissory notes were executed by Titshaw and Healan as members of the company; (ii) the company also executed deeds to secure debt in favor of Freedom Bank, conveying security interests in certain real properties; and (iii) Titshaw and Healan executed personal guaranties. After the company and the guarantors defaulted on the underlying loan obligations, Freedom Bank conducted nonjudicial foreclosure sales upon the real estate securing the loans. In January 2009, within 30 days after the foreclosure sales, Freedom Bank reported the sales to a superior court judge, applied for confirmations, and sought hearings thereon. 1

But prior to the confirmation matters being heard, as the parties agreed below, the Federal Deposit Insurance Corporation (FDIC) was appointed receiver for Freedom Bank. The record shows that the notes and guaranties at issue in these appeals were transferred to Northeast Georgia Bank. And that bank, rather than Freedom Bank, then pursued and ultimately obtained the two confirmation orders appealed here.

In arguing to the superior court that Northeast Georgia Bank was not the proper party to pursue the confirmations, appellants’ *713 counsel relied on language within the confirmation statute, OCGA § 44-14-161:

When any real estate is sold on foreclosure, without legal process, and under powers contained in security deeds, . . . no action may be taken to obtain a deficiency judgment unless the person instituting the foreclosure proceedings shall, within 30 days after the sale, report the sale to the judge of the superior court of the county in which the land is located for confirmation and approval and shall obtain an order of confirmation and approval thereon. 2

Counsel further asserted that the confirmation statute was to be strictly construed as it was in derogation of common law. 3 Thus, counsel summarized, “[0]ur position is that the FDIC as receiver for Freedom Bank is the proper party, is the only proper party.”

1. The appellants contend that the superior court erred in rejecting their position and thus allowing Northeast Georgia Bank to seek the confirmations under OCGA § 44-14-161. We disagree.

The salient question raised by this contention concerns the intendment of the cited statutory language: “person instituting the foreclosure proceedings.” 4 “It is, of course, fundamental that the cardinal rule to guide the construction of laws is, first, to ascertain the legislative intent and purpose in enacting the law, and then to give it that construction which will effectuate the legislative intent and purpose.” 5

Prior to the enactment of [OCGA § 44-14-161’s predecessor], it was the law of Georgia that in the event of insufficient return upon the sale of real estate as collateral, a suit could be maintained ... to collect the deficiency. [The confirmation statute] does not eliminate this claim but subjects it to the condition that the foreclosure sale under power be given judicial approval. From the perspective of history and a consideration of the economic factors then extant, it is evident the intendment of the General Assem *714 bly in 1935, in adopting this [statute’s predecessor], was to provide for debtor relief. 6

Thus, as the Supreme Court of Georgia has more recently summarized, “OCGA § 44-14-161 is a debtor’s relief statute and is in derogation of the creditor’s common-law right to seek a deficiency judgment after nonjudicial foreclosure under power of sale.” 7 The Court has held that the statute allows for a court “to pass upon the notice, advertisement and regularity of the sale and to re-insure that the property was sold for a fair value. [The statute] provides debtors with formidable protection against gross deficiency judgments.” 8 And regarding the narrow applicability of the confirmation statute, the Court has explained:

The only purpose of the confirmation statute is to subject the creditor’s potential deficiency claim to the condition that the foreclosure sale under power be given judicial approval. The confirmation proceeding does not result in a personal judgment and it does not adjudicate the title of the property sold. Except as to the confirmed amount of the sale, it does not establish the liability of any party with regards to the indebtedness. 9

In this case, it is undisputed that Freedom Bank — the original creditor of the underlying notes and the entity that instituted the foreclosure proceedings — assigned the notes to Northeast Georgia Bank.

An assignment is an absolute, unconditional, and completed transfer of all right, title, and interest in the property that is the subject of the assignment. . . . Moreover, in the absence of a contrary intention, an assignment usually passes as incidents all ancillary remedies and rights of *715 action which the assignor had or would have had for the enforcement of the right or chose assigned. 10

No contrary intention is shown in the relevant documents. Instead, each note defined “Borrower” as Jackson County Investment Ventures, and “Lender” to include Freedom Bank, as well as “its successors and assigns.” 11

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Janet Hildebrand v. Bank of America, N.A.
Court of Appeals of Georgia, 2015
Hildebrand v. Bank of America, N.A.
772 S.E.2d 790 (Court of Appeals of Georgia, 2015)
Cumberland Contractors, Inc. v. State Bank & Trust Co.
755 S.E.2d 511 (Court of Appeals of Georgia, 2014)
Peoples Bank v. Harp
948 F. Supp. 2d 1335 (N.D. Georgia, 2013)
Atreus Communities of America, LLC v. Keybank National Ass'n
706 S.E.2d 107 (Court of Appeals of Georgia, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
697 S.E.2d 837, 304 Ga. App. 712, 2010 Fulton County D. Rep. 2217, 2010 Ga. App. LEXIS 604, Counsel Stack Legal Research, https://law.counselstack.com/opinion/titshaw-v-northeast-georgia-bank-gactapp-2010.