Wells Fargo Bank v. Scicchitano, M.

CourtSuperior Court of Pennsylvania
DecidedJune 22, 2018
Docket3056 EDA 2017
StatusUnpublished

This text of Wells Fargo Bank v. Scicchitano, M. (Wells Fargo Bank v. Scicchitano, M.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wells Fargo Bank v. Scicchitano, M., (Pa. Ct. App. 2018).

Opinion

J-A10023-18

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT I.O.P. 65.37

WELLS FARGO BANK, N.A. : IN THE SUPERIOR COURT OF SUCCESSOR BY MERGER TO : PENNSYLVANIA WACHOVIA BANK, N.A. : : : v. : : : MARZAILE SCICCHITANO : No. 3056 EDA 2017 : Appellant :

Appeal from the Order Entered August 25, 2017 In the Court of Common Pleas of Delaware County Civil Division at No(s): 2014-11559

BEFORE: GANTMAN, P.J., McLAUGHLIN, J., and RANSOM*, J.

MEMORANDUM BY McLAUGHLIN, J.: FILED JUNE 22, 2018

In this mortgage foreclosure action, Marzaile Scicchitano has appealed

from an order that denied his Petition to Set Aside Sheriff’s Sale. He sought

to undo the sheriff’s sale because of alleged misrepresentations in

communications from Appellee, Wells Fargo Bank, N.A. Successor by Merger

to Wachovia Bank, N.A. (“Bank”), allegedly causing him to believe that the

sale would not proceed. He also contended that the sale price at the sheriff’s

sale was too low. The Court of Common Pleas, the Honorable Chad F. Kenney,

denied the petition. Judge Kenney concluded that Scicchitano reasonably

should have known that the sheriff’s sale would proceed. He also rejected

Scicchitano’s price challenge. We affirm based on Judge Kenney’s opinion.

We adopt Judge Kenney’s recitation of the factual and procedural

history. See Trial Court Opinion, filed 10/24/17, at 1-3.

____________________________________ * Retired Senior Judge assigned to the Superior Court. J-A10023-18

Scicchitano raises four issues on appeal:

1. Did the Court abuse its discretion or otherwise err in denying [Scicchitano’s] Petition to Set Aside Sheriff’s Sale where, after a hearing, it was undisputed that (a) [Bank] last direct communication (in contrast to ongoing communications from [Bank’s] third party attorney which [Bank] instructed [Scicchitano] would occur) misrepresented that [Bank] (i) “received the documentation you sent us supporting your request for mortgage assistance...;” (ii) “as part of the foreclosure process, you may receive notices from a third party attorney delivered by mail or see steps being taken to proceed with foreclosure...;” and (iii) “if your loan has been referred to foreclosure and you have submitted all required documentation, we will not conduct a foreclosure sale while your documents are being reviewed” ((i), (ii) and (iii) being hereinafter referred to as the “Final Communication Misrepresentations”); and (b) despite those Final Communication Misrepresentations, Appellant [sic], without any further direct communication, proceeded with a sheriff’s sale and sold [Scicchitano’s] property at 61.8% of it’s [sic] appraised Fair Market Value of $100,000, approximately 49% of [Bank’s] internal value and 30% of the total debt alleged to be due from [Scicchitano] to [Bank]?

2. Did the Court abuse its discretion or otherwise err in not finding that the combination of (a) the grossly inadequate or inadequate price; and (b) the irregularities in the notice process, consisting of (i) the Final Communication Misrepresentation, and (ii) two prior continuances of the ultimate sale unilaterally effectuated by [Bank] (which created a false sense of security in [Scicchitano] that the ultimate sale would also be continued based on the Final Communication Misrepresentation); created an irregularity in the notice procedure and denied [Scicchitano] of due process rights, and was sufficient cause to set aside the sale?

3. Did the Court abuse its discretion or otherwise err in not granting [Scicchitano’s] Petition to Set Aside Sheriff’s Sale by in effect inequitably and unfairly shifting the burden to [Scicchitano] to (a) have understood the Final Communication Misrepresentation was a misrepresentation,

-2- J-A10023-18

and (b) correct [Bank’s] Final Communication Misrepresentation?

4. Did the Court err by allowing undue bias against other alleged misbehaviors of [Scicchitano] that are not relevant to the due process question to unduly influence the determination of whether the substantially below value sale and the irregularities and defect in notice created by the Final Communication Misrepresentation and prior unilateral continuances establish sufficient cause to set aside the sale and violate [Scicchitano’s] due process rights?

Appellant’s Br. at 4-6.

Scicchitano waived his second and fourth issues by not raising them

below. See Pa.R.A.P. 302. They are meritless in any event. As to the second

issue, Judge Kenney did not err in not considering the combined effect of

Scicchitano’s sale price and misrepresentation arguments. The issues are not

logically related – that is, any misunderstanding on Scicchitano’s part about

whether the sale would proceed had nothing to do with the price obtained at

the sale, and vice-versa – and to the extent either argument would carry any

weight, it would not reinforce the other. Regarding the fourth issue, as we

explain below, Judge Kenney only mentioned Scicchitano’s failure to make

payments as one of the reasons that Scicchitano reasonably should have

known that the foreclosure sale would occur.

We affirm Scicchitano’s remaining issues based on Judge Kenney’s

opinion. A petition to set aside a sheriff’s sale is a request for equitable relief

addressed to the sound discretion of the Court of Common Pleas. Blue Ball

Nat’l Bank v. Balmer, 810 A.2d 164, 167 (Pa.Super. 2002); Greater

Pittsburgh Bus. Dev. Corp. v. Braunstein, 568 A.2d 1261, 1263 (Pa.Super.

-3- J-A10023-18

1989). The petitioner bears the burden of proving circumstances warranting

the Court of Common Pleas to exercise its equitable powers and set aside the

sale. Id. We will reverse the Court of Common Pleas’ decision not to set aside

a sheriff’s sale only for a clear abuse of discretion. Kaib v. Smith, 684 A.2d

630, 631-32 (Pa.Super. 1996).

Scicchitano argues that the Bank’s alleged misrepresentations led him

to believe that the sheriff’s sale would not take place. Scicchitano had applied

to the Bank to participate in a loan assistance program. The Bank first advised

him by letter that “[b]ecause you have not provided us with all the required

documentation to complete the application, we are not able to offer you

assistance options.” Letter from Bank to Appellant of 12/16/16, at 1, R.191a.

The Bank sent a subsequent letter three days later, stating that “[i]f your loan

has been referred to foreclosure and you have submitted all required

documentation, we will not conduct a foreclosure sale on this loan while your

documents are being reviewed. . . .” Letter from Bank to Appellant of

12/19/16, at 1, R.58a. This letter also advised Scicchitano that “[a]s part of

the foreclosure process,” he might “receive notices from a third-party attorney

delivered by mail or see steps being taken to proceed with a foreclosure sale

of your home.” Id. Scicchitano argues that the second letter misled him and

caused him to incorrectly believe that the sheriff’s sale would not take place

as scheduled.

Regarding the sale price, Scicchitano argues that the amount ($61,800)

was grossly inadequate because it was 61.8% of the Bank’s appraisal of the

-4- J-A10023-18

property’s value ($100,000), and 49% of the Bank’s internal valuation

($125,000).

Scicchitano also contends that Judge Kenney improperly put the burden

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Related

Blue Ball National Bank v. Balmer
810 A.2d 164 (Superior Court of Pennsylvania, 2002)
Kaib v. Smith
684 A.2d 630 (Superior Court of Pennsylvania, 1996)
Bank of America v. Estate of Hood
47 A.3d 1208 (Superior Court of Pennsylvania, 2012)
Greater Pittsburgh Business Development Corp. v. Braunstein
568 A.2d 1261 (Superior Court of Pennsylvania, 1989)

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Wells Fargo Bank v. Scicchitano, M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/wells-fargo-bank-v-scicchitano-m-pasuperct-2018.