WELLS FARGO BANK NA v. KANE

CourtDistrict Court, D. Maine
DecidedJune 12, 2025
Docket1:24-cv-00263
StatusUnknown

This text of WELLS FARGO BANK NA v. KANE (WELLS FARGO BANK NA v. KANE) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
WELLS FARGO BANK NA v. KANE, (D. Me. 2025).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF MAINE

WELLS FARGO BANK, N.A, ) ) Plaintiff ) ) v. ) No. 1:24-cv-00263-LEW ) DANIELLE L. KANE & CHELSEA ) KANE ) ) Defendants )

ORDER ON DEFENDANT’S MOTION TO DISMISS

Plaintiff Wells Fargo Bank is the current holder of a promissory note secured by Defendant Danielle Kane’s mortgage of her property. In dispute is how much of Danielle’s property the mortgage covers. Wells Fargo seeks reformation of the mortgage and underlying deed to include all of the property. Before the Court is Plaintiff’s Motion to Dismiss (ECF No. 7) the reformation claim. After careful review of the pleadings and motion papers, and with the benefit of oral argument, Defendant’s Motion is granted. BACKGROUND1 Decades ago, Danielle Kane came to own the property of 3909 West River Road in Kennebec by way of two deeds. One deed conveyed a parcel containing Danielle’s current home. The other deed conveyed a parcel containing an orchard. Originally the sole owner,

1 This background is drawn from the Complaint (ECF No. 1), Defendant Danielle Kane’s Motion to Dismiss (ECF No. 7), Plaintiff’s Response in Opposition (ECF No. 9), Defendant’s Response (ECF No. 10), and Danielle later executed the “vesting deed” that transferred a portion of her interest to her then-husband Joseph. At the same time, Joseph executed a promissory note with a

brokerage. To secure the note, Danielle and Joseph executed a mortgage of their property. Neither the vesting deed nor the mortgage includes a legal description of the home parcel. They include only the description of the orchard parcel. Fifteen years ago, Danielle and her husband divorced. The Divorce Judgment provided that Danielle would “be responsible for the mortgage on the marital home to Wells Fargo.” Divorce J. (ECF No. 9-1 at 2). In 2015, Joseph passed away. In 2016,

Danielle Kane defaulted on the mortgage. Through a series of assignments, Wells Fargo now holds the note and has come to collect. It initiated a foreclosure action against Danielle Kane and the executor of Joseph’s estate, Chelsea Kane. Chelsea has since defaulted. Order Granting Mot. for Entry of Default (ECF No. 14). Before foreclosing, Wells Fargo would like this Court to reform the vesting deed

and mortgage to encompass both the home and orchard parcels rather than just the orchard parcel. It maintains that the loan papers were intended to encompass the entire property and that the encumbrance of only a portion of the property was a mutual mistake. Danielle now moves to dismiss Wells Fargo’s reformation claim. DISCUSSION

Danielle argues that the applicable statute of limitations bars Wells Fargo from bringing its reformation claim. An affirmative defense, such as the statute of limitations, “may be raised in an action for failure to state a claim.” Blackstone Realty LLC v. F.D.I.C., 244 F.3d 193, 197 (1st Cir. 2001). Danielle must show the facts establishing her statute of limitations defense are “obvious on the face of [Wells Fargo’s] pleadings.” Aldahonda- Rivera v. Parke Davis & Co., 882 F.2d 590, 592 (1st Cir. 1989). “[T]he Complaint,

together with any other documents appropriately considered [at the motion to dismiss stage], must ‘leave no doubt’ that the plaintiff's action is barred by the asserted defense.” Blackstone, 244 F.3d at 197 (quoting LaChapelle v. Berkshire Life Ins. Co., 142 F.3d 507, 508 (1st Cir. 1998)). The parties’ arguments on whether the claim is time-barred boil down to arguments over which statute of limitations applies here. Danielle submits it is 14 M.R.S.A. § 752,

which provides “[a]ll civil actions shall be commenced within 6 years after the cause of action accrues.” Wells Fargo insists it is 14 M.R.S.A. § 751, which gives a twenty-year limitation for “personal actions on contracts or liabilities under seal, promissory notes . . . or on the bills, notes, or other evidences of a debt issued by a bank.” Wells Fargo’s Complaint makes it clear that the allegedly mistaken vesting deed and mortgage were

signed eighteen years before this case began and, it argues, that is when the limitations clock began ticking. See McNicholas v. Bicford, 612 A.2d 866, 869 (Me. 1992) (“An injured party’s cause of action accrues when the party suffers a judicially cognizable injury.”). If the six-year statute of limitations applies, Wells Fargo has no reformation claim.

I agree with Danielle that the six-year statute of limitations applies here. Reformation of a deed is an equitable remedy. Tibbetts v. Pelotte, 427 A.2d 956 (Me. 1981). “[A]ll civil actions, including equitable claims, must be commenced within six years after the cause of action accrues, unless a more particularized statute applies.” United States Bank Nat’l Ass’n v. Adams, 102 A.3d 774, 776 (Me. 2014) (citing 14 M.R.S.A. § 752). Section 751, however, is not a more particularized statute. In Adams, the Maine Law

Court rejected the argument that equitable claims based on an underlying note and mortgage were subject to Section 751’s twenty-year limitation period. Id. at 776 n.2 (denying lender’s claim for an equitable lien against joint tenant who did not sign note or mortgage). There, the note could not be enforced against the joint tenant who was not a signatory of the note. Here, in contrast, Wells Fargo seeks to enforce a note and mortgage, but to do so through equitable reformation of the same. Still, I agree with Danielle that the

claim, although based on a note and mortgage, is an equitable claim subject to the six-year statute of limitations. Wells Fargo attempts to distinguish Adams as applying the six-year statute of limitations only because the plaintiff in Adams brought an equitable lien claim instead of a foreclosure claim. In Wells Fargo’s view, because it seeks foreclosure alongside its

equitable reformation claim, the reformation claim is a foreclosure action entitled to the twenty-year statute of limitations. Not so. Reformation is separate from foreclosure and is subject to the six-year statute of limitations. See Bank of N.Y. Mellon v. King, 2018 Me. Super. LEXIS 124, at *6 (applying six-year statute of limitations to reformation claim brought alongside foreclosure action); U.S. Bank US Bank Tr. Nat’l Ass’n v. Tenpenny, 659

F. Supp. 3d 62, 76-77 (D. Me. 2023) (“The real issue is whether a claim for reformation of mortgage constitutes a ‘personal action[ ] on’ the [mortgage] for purposes of section 751. I conclude that it does not because courts have, not surprisingly, construed “personal action[ ] on” a mortgage to include only proceedings enforcing a mortgage, rather than any action that relates to a mortgage.”) (citations omitted).2 I also observe that the Maine Supreme Court has uncritically upheld application of the six-year statute of limitation to

an equitable claim by a party to a deed who sought recission, merely remanding the question of whether the six-year statute was met to the trial court for its resolution based on evidence of the claimant’s diminished capacity. Bowden v. Grindle, 651 A.2d 347, 351 (Me. 1994). Wells Fargo raises a last-ditch effort to preserve its reformation claim by arguing Danielle is judicially estopped from raising a statute of limitations defense. “[J]udicial

estoppel ‘is an equitable doctrine invoked by a court at its discretion.’” New Hampshire v.

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WELLS FARGO BANK NA v. KANE, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wells-fargo-bank-na-v-kane-med-2025.