UNITED MIDWEST SAVINGS BANK dba MIDWEST BUSINESS C v. RAIFFE

CourtUnited States Bankruptcy Court, D. Arizona
DecidedMay 8, 2020
Docket2:19-ap-00098
StatusUnknown

This text of UNITED MIDWEST SAVINGS BANK dba MIDWEST BUSINESS C v. RAIFFE (UNITED MIDWEST SAVINGS BANK dba MIDWEST BUSINESS C v. RAIFFE) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
UNITED MIDWEST SAVINGS BANK dba MIDWEST BUSINESS C v. RAIFFE, (Ark. 2020).

Opinion

Dated: May 8, 2020 Daniel P. Collins, Bankruptcy Judge 3 □□ 4 UNITED STATES BANKRUPTCY COURT 5 DISTRICT OF ARIZONA 6 || Inre: ) Chapter 7 Proceedings ) DAVID M. RAIFFE, ) Case No.: 2:18-bk-15086-DPC 8 ) 9 Debtor. ) Adversary No.: 2:19-ap-00098-DPC UNITED MIDWEST SAVINGS ) 10 || BANK, dba MIDWEST BUSINESS _ ) UNDER ADVISEMENT ORDER 1 || CAPITAL, ) ) [NOT FOR PUBLICATION] 12 Plaintiff, ) ) 13 v. ) 14 ) 15 || DAVID M. RAIFFE, ) ) 16 Defendant. ) 17 This adversary proceeding (““Adversary Proceeding”) involves a loan for $400,000 18 || Loan”) from Plaintiff, Midwest Savings Bank (‘Plaintiff’) to Defendant, David M. 19 || Raiffe (‘Defendant” or “Debtor’’) for him to acquire a dental practice in Hamilton, Ohio. 20 || Plaintiff claims the Loan is non-dischargeable pursuant to 11 U.S.C. § 523(a)(2)(B)! 21 || because Defendant submitted a false personal financial statement (the “PFS”) as part of 22 || his Loan application. After considering the testimony and exhibits introduced at trial as 23 || well as the oral arguments and post-trial briefs of counsel, this Court finds that the Loan 24 a non-dischargeable debt under § 523(a)(2)(B).” 25 26 27 28 ' Unless indicated otherwise, statutory citations refer to the U.S. Bankruptcy Code, 11 U.S.C. §§ 101 — 1532. * This Order constitutes this Court’s findings of fact and conclusions of law pursuant to Rule 7052 of the Rules of Bankruptcy Procedure.

1 I. BACKGROUND 2 On March 15, 2019, Plaintiff commenced this Adversary Proceeding by filing a 3 three-count complaint3 against Defendant. On April 22, 2019, Defendant filed his 4 answer.4 5 On December 18, 2019, Defendant filed a motion in limine (“Motion in Limine”)5 6 requesting that the Court bar any introduction of evidence regarding Defendant’s income 7 to debt ratio and use of such ratios by Plaintiff in the Loan application process. Plaintiff 8 filed its response,6 Defendant filed his reply.7 After a hearing on Defendant’s Motion in 9 Limine the Court ruled that no evidence was to be presented at trial concerning ratios, 10 formulas, debt service coverage or debt to income ratios considered by Plaintiff in 11 approving the Loan but that evidence of cash flows considered by Plaintiff would be 12 admissible.8 13 On January 17, 2020, the parties filed their joint pre-trial statement.9 Trial was held 14 on January 27, 2020 and January 28, 2020. Plaintiff submitted its Post-Trial Brief,10 15 Defendant submitted his Response to Plaintiff’s Post-Trial Brief,11 and Plaintiff submitted 16 its Reply.12 17 18 II. JURISDICTION 19 This Court has jurisdiction under 28 U.S.C. § 157(b)(2)(I). The parties have 20 consented to this Court’s jurisdiction to enter final orders.13 21 22

23 3 DE 1. “DE” references a docket entry in this Adversary Proceeding 2:19-ap-00098-DPC. Prior to the start of trial, Plaintiff orally moved to dismiss Count I (§ 523(a)(4)) and Count II (§ 523(a)(6)). 24 4 DE 7. 5 DE 16. 25 6 DE 17. 7 DE 19. 26 8 DE 25. 9 DE 23. 27 10 DE 30. 11 DE 31. 28 12 DE 32. 13 Id. at page 2, lines 1 – 2 and lines 8 – 9. 1 2 III. LEGAL ANAYLSIS 3 A. § 523(a)(2)(B) 4 The Bankruptcy Code provides for a chapter 7 discharge of an individual debtor’s 5 debts14 but “limits the opportunity for a completely unencumbered new beginning to the 6 honest but unfortunate debtor.”15 Section 523 enumerates nineteen exceptions to 7 discharge. Section 523(a)(2)(B) is the only discharge exception at issue in this case. That 8 section states:

9 (a) A discharge under section 727, 1141, 1228(b), or 1328(b) of this title 10 does not discharge an individual debtor for any debt – … 11 (2) for money, property, services, or an extension, renewal, or refinancing 12 of credit, to the extent obtained by – … 13 (B) use of a statement in writing – 14 (i) that is materially false; (ii) respecting the debtor’s or an insider’s financial condition; 15 (iii) on which the creditor to whom the debtor is liable for such 16 money, property, services, or credit reasonably relied; and (iv) that the debtor caused to be made or published with intent to 17 deceive… 18 19 The party claiming non-dischargeability has the burden of proving each of these 20 elements by a preponderance of the evidence.16 The Ninth Circuit has articulated a 21 § 523(A)(2)(B) claim as consisting of the following seven elements:

22 (1) a representation of fact by the debtor, (2) that was material, (3) that the 23 debtor knew at the time to be false, (4) that the debtor made with the intention of deceiving the creditor, (5) upon which the creditor relied, (6) 24 that the creditor’s reliance was reasonable, and (7) that damage 25 proximately resulted from the representation.17 26

27 14 11 U.S.C. § 727. 15 Grogan v. Garner, 498 U.S. 279, 286-87 (1991). 28 16 Id. at 291. 17 In re Candland, 90 F.3d 1466, 1469 (9th Cir. 1996)(citing In re Siriani, 967 F.2d 302, 304 (9th Cir. 1992)). 1 “Material misrepresentations for [§ 523(a)(2)(B) purposes] are substantial 2 inaccuracies of the type which would generally affect a lender’s or guarantor’s 3 decision.”18 A material misrepresentation alone is not enough to deny discharge. The 4 debtor also must have known the misrepresentation to be false, the creditor must have 5 reasonably relied on the misrepresentation and the misrepresentation must have 6 proximately caused the damages suffered.19 7 The Ninth Circuit does not impose a duty on creditors to engage in extensive 8 investigations concerning a borrower’s written financial statements but, rather, has found 9 that creditors are entitled to reasonably rely on false financial statements where minimal 10 investigation has occurred.20 “Lenders do not have to hire detectives before relying on 11 borrowers’ financial statements…[A]lthough a creditor is not entitled to rely upon an 12 obviously false representation of the debtor, this does not require him or her to view each 13 representation with incredulity requiring verification.”21 When there is evidence of 14 materially fraudulent statements, little investigation is required for a creditor to have 15 reasonably relied on the representations.22 Once a court determines that a debtor submitted 16 a materially false financial statement to lender, the reasonableness requirement under § 17 523(a)(2)(B) is a low standard for the creditor to meet and only intended as an obstacle 18 for creditors acting in bad faith.23 19 20 B. Application of Agency Law 21 The Defendant claims his PFS24 submitted to Plaintiff was prepared not by him, 22 but, rather, by his employee Opal Anderson (“Anderson”). Plaintiff contends Anderson 23 was Defendant’s agent and that Defendant is bound by her actions taken on his behalf. 24 18 Id. at 1470. 25 19 Id. 20 Id. at 1471 (finding that creditor who compared address and social security number on a financial statement with 26 a credit report and checked the credit report for outstanding judgments reasonably relied on a debtor’s false financial statement). 27 21 In re Figge, 94 B.R. 654, 665 (Bankr. S.D. Cal. 1988), aff’d 928 F.2d 1136 (9th Cir. 1991)(table). 22 In re Gertsch, 237 B.R. 160, 170 (9th Cir. BAP 1999). 28 23 Id. (citing In re Bonnanzio, 91 F.3d 296, 301 (2d. Cir. 1996)). 24 Trial Exhibit (“Ex.”) 1.

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UNITED MIDWEST SAVINGS BANK dba MIDWEST BUSINESS C v. RAIFFE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-midwest-savings-bank-dba-midwest-business-c-v-raiffe-arb-2020.