U. S. Bank v. Otis Phillips

CourtCourt of Appeals of Georgia
DecidedNovember 28, 2012
DocketA12A0957
StatusPublished

This text of U. S. Bank v. Otis Phillips (U. S. Bank v. Otis Phillips) 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
U. S. Bank v. Otis Phillips, (Ga. Ct. App. 2012).

Opinion

FOURTH DIVISION MILLER, P. J., DOYLE, P.J. and Boggs, J.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. (Court of Appeals Rule 4 (b) and Rule 37 (b), February 21, 2008) http://www.gaappeals.us/rules/

November 28, 2012

In the Court of Appeals of Georgia A12A0957. U.S. BANK, N.A. v. OTIS WAYNE PHILLIPS.

MILLER, Presiding Judge.

This case arises out of foreclosure proceedings instituted by U. S. Bank, N.A.

against the residence owned by Otis Wayne Phillips. Phillips filed suit seeking

damages and an injunction to prevent foreclosure, alleging that U. S. Bank had failed

to properly evaluate his request for a loan modification under the federal Home

Affordable Modification Program (“HAMP”). Specifically, Phillips’s complaint set

forth claims for third-party beneficiary breach of contract; breach of the implied

covenant of good faith and fair dealing; negligent implementation of HAMP; and

wrongful attempted foreclosure. U.S. Bank filed a motion to dismiss Phillips’s claims,

arguing that he failed to state a claim upon which relief can be granted. The trial court

denied U. S. Bank’s motion. We granted U. S. Bank’s application for interlocutory appeal to consider the

propriety of the trial court’s order. The instant appeal ensued. U. S. Bank contends

that dismissal of the complaint was required as a matter of law since Phillips was not

a third-party beneficiary to the HAMP contract between U. S. Bank and the federal

government; HAMP does not provide a private right of action to Phillips; and

Phillips’s claims failed to set forth viable causes of action. For the reasons that

follow, we affirm the dismissal as to the claims for third-party beneficiary breach of

contract, breach of the implied covenant of good faith and fair dealing, and negligent

implementation of HAMP. We vacate the trial court’s decision as to the claim for

wrongful attempted foreclosure and remand this case pending the Georgia Supreme

Court’s issuance of a decision in You v. JP Morgan Chase Bank, N. A., Case No.

S13Q0040 (docketed Sept. 13, 2012). Accordingly, the trial court’s decision is

reversed in part and vacated in part, and this case is remanded with direction.

Under OCGA § 9-11-12 (b) (6), a motion to dismiss for failure to state a claim upon which relief can be granted should not be sustained unless (1) the allegations of the complaint disclose with certainty that the claimant would not be entitled to relief under any state of provable facts asserted in support thereof; and (2) the movant establishes that the claimant could not possibly introduce evidence within the framework of the complaint sufficient to warrant a grant of the relief sought. In

2 deciding a motion to dismiss, all pleadings are to be construed most favorably to the party who filed them, and all doubts regarding such pleadings must be resolved in the filing party’s favor.

(Citation and punctuation omitted.) Anderson v. Daniel, 314 Ga. App. 394, 395 (724

SE2d 401) (2012).

So viewed, the complaint alleged that in December 2007, Phillips executed a

security deed pledging his residence located at 437 Barton Lane, Villa Rica, Georgia,

as collateral for a loan issued by PHM Financial Incorporated d/b/a Professional

Home Mortgage. The security deed listed Mortgage Electronic Registration Systems

(“MERS”) as the beneficiary. U.S. Bank later became the servicer for the mortgage

loan.

Phillips subsequently was unable to make his mortgage payments and defaulted

on the loan. In 2010, Phillips requested a loan modification under HAMP. U. S. Bank

had signed a Servicer Participation Agreement (“SPA”) with the federal government,

agreeing to participate in HAMP. The SPA incorporated a “Program Documentation,”

which set forth guidelines, procedures, instructions, documentation, and directives

issued by the U. S. Department of Treasury, Fannie Mae, or Freddie Mac in

connection with the duties of participating servicers. The Program Documentation

3 required participating servicers to evaluate delinquent loans for HAMP modifications

and to collect the borrower’s financial information to determine whether HAMP was

appropriate for the borrower. Phillips alleged that U. S. Bank failed to properly

evaluate his application for a HAMP modification. U.S. Bank denied Phillips’s

application and attempted to foreclose on his residence.

Phillips filed the instant complaint against U. S. Bank, alleging four causes of

action: (1) third-party beneficiary breach of contract; (2) breach of the implied

covenant of good faith and fair dealing; (3) negligent implementation of HAMP; and

(4) wrongful attempted foreclosure. We address each of Phillips’s claims in turn

below.

1. Third-Party Beneficiary Breach of Contract. U. S. Bank contends that

Phillips lacks standing to pursue a breach of contract claim based upon HAMP since

HAMP did not create an actionable third-party beneficiary right. We agree.

Phillips does not claim that he was a party to the HAMP SPA between U. S.

Bank and the federal government. Rather, Phillips claims that he is entitled to sue for

enforcement of the HAMP SPA as a third-party beneficiary.

[I]n order for a third party to have standing to enforce a contract under OCGA § 9-2-20 (b), it must clearly appear from the contract that

4 it was intended for his benefit. The mere fact that he would benefit incidentally from performance of the agreement is not alone sufficient. There must be a promise by the promisor to the promisee to render some performance to a third person, and it must appear that both the promisor and the promisee intended that the third person should be the beneficiary.

(Punctuation and footnote omitted.) Danjor, Inc. v. Corporate Constr., Inc., 272 Ga.

App. 695, 697 (1) (613 SE2d 218) (2005). Although the Georgia state appellate

courts have not previously addressed the issue as to whether HAMP created third-

party beneficiary standing to enforce HAMP, the federal courts in Georgia have

decided this issue and have consistently rejected this claim.

In Miller v. Chase Home Fin., LLC, 677 F.3d 1113, 1115-1116 (III) (11th Cir.

2012), the federal appellate court summarized the legislative purpose for the

enactment of HAMP as follows:

During the economic crisis of 2008, Congress passed the Emergency Economic Stabilization Act of 2008 (EESA), 12 U.S.C. §§ 5201-5261. EESA charges the Secretary of the United States Department of the Treasury with acting in a manner that “preserves homeownership and promotes jobs and economic growth.” Id. § 5201(2)(B). To this end, the Department of the Treasury created the Making Home Affordable Program, a program that included HAMP.

5 HAMP is designed to prevent avoidable home foreclosures by incentivizing loan servicers to reduce the required monthly mortgage payments for certain struggling homeowners. Servicers are obliged to abide by guidelines promulgated by the Secretary when determining a mortgagor’s eligibility for a permanent loan modification. U.S. Dept.

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Miller v. Chase Home Finance, LLC
677 F.3d 1113 (Eleventh Circuit, 2012)
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610 S.E.2d 352 (Court of Appeals of Georgia, 2005)
Edwards v. Aurora Loan Services, LLC
791 F. Supp. 2d 144 (District of Columbia, 2011)
Jenkins v. Wachovia Bank, N.A.
724 S.E.2d 1 (Court of Appeals of Georgia, 2012)
Anderson v. Daniel
724 S.E.2d 401 (Court of Appeals of Georgia, 2012)
Danjor, Inc. v. Corporate Construction, Inc.
613 S.E.2d 218 (Court of Appeals of Georgia, 2005)

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