Voss v. Quicken Loans, L.L.C.

2024 Ohio 12
CourtOhio Court of Appeals
DecidedJanuary 5, 2024
DocketC-230065
StatusPublished
Cited by1 cases

This text of 2024 Ohio 12 (Voss v. Quicken Loans, L.L.C.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Voss v. Quicken Loans, L.L.C., 2024 Ohio 12 (Ohio Ct. App. 2024).

Opinion

[Cite as Voss v. Quicken Loans, L.L.C., 2024-Ohio-12.]

`IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

SAMUEL VOSS, : APPEAL NO. C-230065 TRIAL NO. A-2002899 Plaintiff-Appellee, : vs. : QUICKEN LOANS, LLC, O P I N I O N.

and :

MORTGAGE ELECTRONIC : REGISTRATION SYSTEMS, INC.,

Defendants-Appellants. :

Civil Appeal From: Hamilton County Court of Common Pleas

Judgment Appealed From Is: Affirmed

Date of Judgment Entry on Appeal: January 5, 2024

Markovits, Stock & DeMarco, LLC, W.B. Markovits, Terence R. Coates, Justin C. Walker, Dylan J. Gould, Wolterman Law Office, LPA, and Matthew C. Metzger, for Plaintiff-Appellee,

Goodwin Procter LLP, William M. Jay, Brooks R. Brown, Joseph Yenouskas, Frost Brown Todd LLC, Nathaniel L. Truit, James C. Frooman, Manley Burke LPA and Timothy M. Burke, for Defendants-Appellants. OHIO FIRST DISTRICT COURT OF APPEALS

BOCK, Judge.

{¶1} Defendants-appellants Quicken Loans, LLC, now known as Rocket

Mortgage, LLC, and Mortgage Electronic Registration Systems, Inc., (collectively

“Rocket Mortgage”) challenge the trial court’s decision to grant plaintiff-appellee

Samuel Voss’s motion to certify a class in this action, which seeks damages for Rocket

Mortgage’s violations of Ohio’s mortgage-recording statute, R.C. 5301.36.

{¶2} First, Rocket Mortgage argues that a recent amendment to R.C.

5301.36(C), which barred class recovery of statutory damages for statutory violations

that occurred in 2020, warranted a denial of Voss’s motion. Second, Rocket Mortgage

argues that Voss and the class lack standing to raise claims for violations of the statute.

Third, Rocket Mortgage claims that the trial court abused its discretion when it found

that common issues predominate the class.

{¶3} We hold that the trial court properly considered the version of R.C.

5301.36(C) that was in effect at the time of its decision. We also hold that the

legislature conferred standing on parties like Voss under R.C. 5301.36(C)(1). Finally,

we hold that the trial court reasonably determined that common issues of law and fact

predominate the class.

I. Facts and Procedure

{¶4} On February 5, 2020, plaintiff-appellee Samuel Voss purchased real

property at 486 Stanley Avenue in Cincinnati, Ohio, from Donald Dow, Jr. Dow had

purchased the property in 2016 with a loan from Rocket Mortgage, secured by a

mortgage with Mortgage Electronic Registration Systems, Inc., (“MERS”). Dow used

the proceeds of the sale to satisfy his obligation to Rocket Mortgage.

2 OHIO FIRST DISTRICT COURT OF APPEALS

{¶5} On May 26, 2020, more than 90 days later, Rocket Mortgage mailed the

release of that mortgage as evidence of its satisfaction to the Hamilton County

Recorder’s office. The satisfaction was recorded the next day.

{¶6} Voss sued Rocket Mortgage, alleging a violation of R.C. 5301.36(B).

Under Ohio law, Rocket Mortgage had until May 5, 2020, to record the satisfaction of

the mortgage with the Hamilton County Recorder’s office. For its part, Rocket

Mortgage acknowledges that it recorded the satisfaction of the mortgage 22 days after

the 90-day statutory deadline.

{¶7} Rocket Mortgage removed the case to federal court. See Voss v. Quicken

Loans LLC, S.D.Ohio No. 1:20-cv-756, 2021 U.S. Dist. LEXIS 161380 (Aug. 26, 2021).

Roughly one year later, the federal court remanded the case back to the common pleas

court because the amount in controversy fell well short of 28 U.S.C. 1332’s $75,000

threshold for diversity jurisdiction, and alternatively, because Voss failed to show a

concrete injury for Article III standing under the United States Constitution. Id. at 17.

The trial court denied Rocket Mortgage’s motion for summary judgment

{¶8} Months later, Rocket Mortgage moved for summary judgment, arguing

that Voss lacked standing to sue under Ohio law and that the COVID-19 pandemic

constituted an unforeseen event excusing its noncompliance with the recording

statute. In support, Rocket Mortgage relied on roughly 2,000 pages of deposition

testimony, affidavits, government orders, and an expert report.

{¶9} In response, Voss argued that he had standing under Ohio law, which

recognizes intangible injuries, and under R.C. 5301.36, which confers statutory

standing. And Voss cited mortgage-release documents filed by Rocket Mortgage in

April 2020 with the Hamilton County Recorder’s office to demonstrate that statutory

compliance was possible. 3 OHIO FIRST DISTRICT COURT OF APPEALS

{¶10} The trial court denied Rocket Mortgage’s motion. It addressed Rocket

Mortgage’s standing claim and explained that “R.C. 5301.36(C) states that ‘the

mortgagor of the unrecorded satisfaction and the current owner of the real property

to which the mortgage pertains may recover, in a civil action.’ ” (Emphasis added by

the trial court.) In addition, the trial court found “genuine issues of material fact

existing in determining whether [the statutory violation] was excusable.”

The trial court granted Voss’s motion for class certification

{¶11} In June 2022, Voss moved to certify a class of all mortgagors or current

owners of property that was the subject of a loan issued by Rocket Mortgage, and its

affiliates and subsidiaries, “where the mortgage was satisfied in full, and the

mortgagee did not record an entry of mortgage satisfaction with the applicable county

recorder’s office within 90 days of the date of mortgage satisfaction, from August 19,

2014 through August 19, 2020.” In addition, Voss asked to serve as class

representative. Rocket Mortgage opposed what it described as a perfunctory motion

for class certification, claiming that Voss failed to meet his burdens of production and

persuasion. Voss replied in support of his motion.

{¶12} In January 2023, Rocket Mortgage supplemented its objection to class

certification, arguing that the General Assembly’s amendment to R.C. 5301.36(C),

which was signed into law on January 6, 2023, with an April 6, 2023 effective date,

precluded recovery of statutory damages in class actions for violations of R.C.

5301.36(B) that occurred in 2020.

{¶13} In February 2023, the trial court granted Voss’s motion for class

certification, explaining that the class is ascertainable, violations of the statutory duty

are common issues of law and fact, and questions of law and fact common to the class

predominate. Plus, the trial court found that “retroactive application of the statute is 4 OHIO FIRST DISTRICT COURT OF APPEALS

not permitted and will apply the law as was written when this action was commenced

and is currently written.”

{¶14} Rocket Mortgage appeals in three assignments of error.

II. Law and Analysis

{¶15} First, Rocket Mortgage argues that the trial court improperly failed to

apply R.C. 5301.36(C)(2) to Voss’s motion for class certification. Second, Rocket

Mortgage maintains that Voss and the entire class lack standing to recover for a

violation of R.C. 5301.36. Third, Rocket Mortgage challenges the trial court’s finding

that questions of law or fact common to the class predominate.

The trial court appropriately considered the law in effect as written

{¶16} In its first assignment of error, Rocket Mortgage argues that newly

enacted R.C.

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

Related

Voss v. Quicken Loans, L.L.C.
2026 Ohio 531 (Ohio Supreme Court, 2026)
Ragouzis v. Madison House Condominium Owners Assn., Inc.
2025 Ohio 2797 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 12, Counsel Stack Legal Research, https://law.counselstack.com/opinion/voss-v-quicken-loans-llc-ohioctapp-2024.