Willow Ridge Ltd. Partnership v. Stewart Title Guaranty Co.

706 F. Supp. 477, 1988 U.S. Dist. LEXIS 15758, 1988 WL 148895
CourtDistrict Court, S.D. Mississippi
DecidedApril 20, 1988
DocketCiv. A. E86-0132(L)
StatusPublished
Cited by5 cases

This text of 706 F. Supp. 477 (Willow Ridge Ltd. Partnership v. Stewart Title Guaranty Co.) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Willow Ridge Ltd. Partnership v. Stewart Title Guaranty Co., 706 F. Supp. 477, 1988 U.S. Dist. LEXIS 15758, 1988 WL 148895 (S.D. Miss. 1988).

Opinion

MEMORANDUM OPINION AND ORDER

TOM S. LEE, District Judge.

This action was brought by Willow Ridge Limited Partnership (Willow Ridge), the insured under a policy of title insurance, against Stewart Title Guaranty Company (Stewart Title), the insurer, alleging breach of the policy and seeking actual and punitive damages. The case was tried by the court sitting without a jury. Upon the evidence presented at trial, the court finds as follows.

Plaintiff Willow Ridge purchased an apartment complex within the City of Meridian, Mississippi on April 23, 1985. At the time of its purchase, the apartments were still under construction by Bubber Wallace d/b/a Wallace Builders and Developers. The project was financed by a bond issue of Lauderdale County, Mississippi, which was secured by a first deed of trust in favor of First Alabama Bank and backed by a letter of credit issued in favor of First Alabama Bank by First Guaranty Savings Bank in Hattiesburg, Mississippi. First Guaranty also held a deed of trust on the property. The project, known as Hanover Square, was developed by Bubber Wallace and owned by Hanover Square, Limited, a Wallace entity.

In his efforts to sell the property, Wallace enlisted the aid of Louis Vance, an attorney/businessman, who put him in contact with John Górecki, the individual in charge of acquisitions for Quadel Corporation, a privately held corporation. Quadel determined to acquire the project and formed a limited partnership, Willow Ridge, for purposes of the acquisition. Financing was arranged through the Bank of Meridian for the downpayment of $600,000, together with an assumption by Willow Ridge of the debt under the bonds and the letter of credit. The loan was to be secured by a third deed of trust on the property, and the Willow Ridge principals, Norman Watson and Thomas Webb, executed personal guarantees for the debt.

Ed Tonore, an attorney and an agent for Stewart Title, was retained to perform a title examination and provide a policy of title insurance on the property. Tonore’s examination of title to the property revealed the Bank of Alabama and First Guaranty deeds of trust. Tonore found no liens for laborers or materialmen, but because the project was still under construction, he secured an owners and contractors affidavit from the owner, Bubber Wallace, that there were no unrecorded liens. To-nore issued a commitment to insure the property on April 23, 1985; under instruction from Willow Ridge representatives and with the authority of Stewart Title, Tonore deleted an exception which would otherwise have excluded from coverage liens for *479 material or labor. 1 Consequently, there was coverage for unrecorded material-men’s liens. On May 2, the closing date, 2 Willow Ridge took the property by warranty deed, which was recorded on that date, and an owner’s policy was issued in favor of Willow Ridge by Tonore, which, like the commitment, did not include the standard exception for unrecorded materialmen’s liens.

After Willow Ridge purchased the property, materialmen, on July 27, 1985, began filing liens, and from that time until August 14, 1985, approximately $900,000 in alleged materialmen’s and laborors’ liens were filed of record in Lauderdale County against the insured properly. On August 14, Willow Ridge informed Stewart Title that liens were being filed against the insured property, 3 following which Stewart Title on September 17 retained Ronnie Walton of the law firm of Williams, Glover, Walton and MacAlilly to represent the interests of Willow Ridge. 4 However, Walton learned that on September 13 the Bank of Meridian had instituted foreclosure proceedings against the insured property and scheduled the foreclosure sale for October 7. After ruling out other alternatives for remedying the lien problem, Willow Ridge sought to enjoin the foreclosure. At the hearing on October 7, Willow Ridge and the Bank of Meridian entered into an agreement under the terms of which Willow Ridge agreed to dismiss its suit to enjoin in exchange for the Bank of Meridian’s granting Willow Ridge the right of first refusal to buy the property back from the bank upon completion of construction 5 and additionally releasing Willow Ridge principals Webb and Watson from their personal guarantees and the $100,000 letter of credit. The foreclosure sale proceeded and the Bank of Meridian bought the subject property for $100,000.

A clear understanding of the parties’ activities preceding the foreclosure is essential to a resolution of this case. According to Walton, when Dogan originally retained him to represent Willow Ridge, Dogan indicated that he was to file suit against Bub-ber Wallace 6 and to represent the interests of Willow Ridge and Quadel in defense of any suits brought by any materialmen. On September 23, Walton learned of the Bank of Meridian’s pending foreclosure. Faced with the time constraints imposed by virtue of the scheduled foreclosure, Walton began considering alternative ways in which to prevent or at least postpone the foreclosure in an effort to buy time so that an arrangement could be worked out with the subcontractors on their lien claims. His main concern, he testified, was to stop the foreclosure. To that end, Walton had numerous discussions with David Dogan, the subcontractors and the Bank of Meridian.

In his discussions with the Bank of Meridian, the Bank indicated a willingness to discontinue the foreclosure proceeding if Webb and Watson, the principals of Willow Ridge, would furnish additional personal guarantees. However, Walton and Willow *480 Ridge, not wanting to increase the personal exposure of Webb and Watson, concluded that acceptance of the Bank's proposal was not a “practical” method for stopping the foreclosure. Walton additionally tried to persuade the subcontractors, to no avail, that it was in their best interest to take some action to stop the foreclosure.

Another option available to Willow Ridge and the one which Stewart Title believed was the most logical, 7 was to file suit to remove the liens as a cloud on Willow Ridge’s title. Stewart Title thought such a suit would be successful based on its opinion that the liens, which were filed after the date of Willow Ridge’s purchase of the property, were invalid as to Willow Ridge since it was a bona fide purchaser for value without notice. Stewart Title thus requested or instructed that Walton file whatever lawsuits were necessary to remove the liens as clouds. Willow Ridge however, while concurring in the opinion that the liens were invalid, concluded that immediately suing the subcontractors or Bubber Wallace was not an option or at least not a practical one; as a matter of economics, the subcontractors were needed to complete the work on the project. In response to these concerns, Dogan “rescinded” the instructions he had given Walton to file suit to remove cloud and instead informed Walton that Stewart Title would honor the terms and obligations of the policy in defending and prosecuting claims and that Walton should do what he thought was in the best interest of Willow Ridge.

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Bluebook (online)
706 F. Supp. 477, 1988 U.S. Dist. LEXIS 15758, 1988 WL 148895, Counsel Stack Legal Research, https://law.counselstack.com/opinion/willow-ridge-ltd-partnership-v-stewart-title-guaranty-co-mssd-1988.