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byline from charlie hahn: condominium law update, legal league quarterly | spring 2013

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10 Legal League Quarterly States: Michigan Condominium Law Update Get up to speed with Michigan’s latest condo rules and regs. By: Charlie Hahn, Trott & Trott It appears that the continued legal wrangling in Michigan between mortgage servicers and condominium associations may be coming to an end. Ever since a controversial trial court decision in 2005, the Condominium Bar has been promoting an interpretation of the Con- dominium Act that claims that an assignment of the first mortgage after the recording of an association lien results in the mortgage losing its priority, Greenbrooke vs. Hubble & Midfirst Bank, Oakland County No. 12-2005 (11-2-05). This claim was based on the assertion that an assignment was a “conveyance” of an interest in the unit, thus triggering section 211 (MCL 559.211), which requires a fee payoff request to the association. Those who disputed this conclu- sion pointed out that such an interpretation ignores (or at least contradicts) clearly stated language found in other relevant provisions of the act, most notably Sections 211 and 158. The intended effects of this theory were clear: to disrupt the foreclosure of the first mort- gage by causing it to fail to extinguish the junior condominium lien and subsequently subjecting the mortgagee to all past unpaid assessments, late fees, and condominium attorney fees. Unfortunately, this seemingly tenuous legal theory was given additional creditability by the decision of most title insurers to refuse to insure over the junior condominium lien when the first mortgage was foreclosed. This unresolved legal tension led to a number of trial court battles. Despite the fact that a significant majority of the decisions found in favor of the assignee of the first mortgage maintaining its priority posi- tion, the litigious back-and-forth continued. After years of debate, the issue was heard by the Court of Appeals on October 10, 2012, and a published decision was issued on Oc- tober 25, 2012, Coventry Parkhomes Condo- minium Assoc. vs. Federal National Mortgage Association, _____ Mich. App._____, No. 304188 (10-25-2012); reconsideration denied 12-18-12. The Court of Appeals did not agree with the association and upheld normal “race- notice” principles. The strongly worded deci- sion states that there is nothing in the Condo- minium Act that could/should be interpreted to change the longstanding principal that an assignee stands in the shoes of the assignor. During oral arguments, the court displayed little sympathy for the association’s arguments, going so far as to make it clear that, in the opin- ion of the court, such an idea could inject an element of chaos into the mortgage market. While this decision resolves what has been a nagging problem for the mortgage industry—and, in the process, promises to eliminate hundreds of thousands of dollars in improper association charges— other issues continue to generate similar discussion and debate. One of the most noteworthy of these is the issue of precisely when a sheriff ’s deed vests its title. While that question has been consistently answered by dozens of published opinions over the century and a half (and was recently restated in In re Receivership of 11910 South Franklin Rd. 492 Mich. 208, 821 NW2d 503 (7-30-12)), some members of the Condominium Bar continue to argue otherwise. Charles L. Hahn serves as a senior litigation attorney for Trott & Trott, P.C., one of the nation’s premier law firms conducting residential default procedures and applying foreclosure avoidance solution. Contact Hahn at [email protected]. 2. In a series of related cases involving sev- eral mortgages encumbering numerous invest- ment properties, a lender seized rents under the assignment of rents and leases in the mortgages. The borrowers interfered and threatened at least one tenant, so a Petition for Preliminary Injunc- tion was filed, which was granted by agreement of the parties. Despite the Injunction to which the borrowers had consented and which required that rent be turned over to the lender, the bor- rowers continued to interfere with rent flow and pocket the rent. It took two subsequent petitions (both seeking sanctions) and several evidentiary hearings for the Motions judge to issue an Order finding the borrowers in contempt of court; awarding attorneys’ fees to the lender; ordering the turnover of improperly withheld rents; and imposing a per diem interest penalty. Notwith- standing that Order, the borrowers (consistent with prior actions) did not comply. Consequently, the lender filed a fourth petition, seeking a bench warrant. Though a bench warrant was not issued, the Motions judge expressed his annoyance and dissatisfaction with the borrowers on the record at an evidentiary hearing and issued an Order giving the borrowers 30 more days to comply with his nearly nine-month-old contempt Order. Around the last day, the borrowers finally paid the monetary sanctions, but not the interest pen- alty required by the contempt Order. Addition- ally, during the course of those cases, one of the borrowers filed a Chapter 13 bankruptcy, which was frivolous. Not only did Debtor’s Schedules contain misrepresentations, but subsequent filings were not completely truthful. On the lend- er’s Rule 11/9011 motion for sanctions, relying primarily on Section 105(a) of the Bankruptcy Code, and after a hearing on the merits involving the Chapter 13 trustee, the bankruptcy judge, inter alia, barred the debtor from re-filing for six months. Though the lender had the right to also file a Petition for Appointment of Receiver, the lender opted not to do so at the time of referral. It is believed that appointment of a receiver would not have changed the borrowers’ conduct and a receiver would have experienced the same chicanery. However, a significant advantage to a receiver is that it becomes the receiver’s responsibility, not the lender/servicer’s, to handle property management. The lender/servicer would still likely have the headache of paying for a receiver and, thus, the lender/servicer should just assume the worst when authorizing a Petition for Appointment of Receiver: That even if the receivership Order directs borrowers to pay for a receiver, they are not going to comply. 3. In a post-sheriff ’s deed ejectment (evic- tion) case, the borrowers filed a motion to stay lockout, falsely claiming that a lockout occurred. The hearing was continued three times and, each time, the borrowers raised different theories as to why lockout should be stayed. At the third hearing, the borrowers claimed that the loan had been satisfied before sheriff ’s sale by the borrow- ers’ aunt right before she had died. Despite the lender’s argument that such a claim should have been raised in the foreclosure action and not in a subsequent ejectment action, the Motions judge continued the third hearing for the borrowers to assemble and submit evidence of the payoff. At the fourth hearing, only one of the borrowers appeared and he attempted to outright avoid dis- cussing the issue of the payoff. When pressed by the Motions judge, the borrower finally conceded that there never was a payoff. Upon request of the lender’s counsel for a provision in the Court’s Order barring both borrowers from filing any further motions or petitions to postpone or stay lockout, the Motions judge initially declined from including such bar; however, the borrower con- tinued to spar verbally with the judge and never apologized for misrepresenting a material fact to him. This not only angered the Motions judge, resulting in a public on-the-record admonish- ment that the borrowers had “wasted his time,” but also caused the Motions judge to reverse his thinking, as he ended up including the re-filing bar. The Motions judge also warned the borrower on the record that any further motions or peti- tions would result in more severe sanctions. Therefore, under the right set of facts, lenders/servicers can obtain at least a verbal reprimand or, at best, sanctions (monetary or otherwise) for unlawful and/or inappropriate con- duct in a civil case. Sanctions, in particular, can require several motions or petitions and hearings (and are likely appealable in many jurisdictions). However, persistence, an aggressive ap- proach, and reliance on local counsel’s expertise as to when you should fight the good fight can result in tactical advantages, such as: » favorable court orders that serve as precedent; » heightened settlement leverage; » re-filing bars that can preclude the filing of further dilatory motions and/or petitions, which cost time and money to defend; and » a message to borrowers, judges, and the defense bar that lenders/servicers are not afraid to be vigilant and willing to enforce their rights in the face of bad conduct. In fact, the last point above is especially important, as there are individuals in the judi- ciary and defense bar who believe that lenders/ servicers will generally just turn a blind eye to misbehavior in order to minimize attorneys’ fees, court costs, and headline risks. However, by not taking any action or counteraction, lenders/ servicers arguably become enablers to bad apple borrowers and engender a culture of misbehavior. Thus, we should not be completely shocked when borrowers, with or without counsel, intentionally run afoul of the law and push the envelope to see what they can “get away with.” “Borrowers Behaving Badly” continued from page 1

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As seen in the Legal League Quarterly, Spring 2013: Condominium Law Update Get up to speed with Michigan's latest condo rules and regs. By Charlie Hahn Excerpt: It appears that the continued legal wrangling in Michigan between mortgage servicers and condominium associations may be coming to an end. Ever since a controversial trial court decision in 2005, the Condominium Bar has been promoting an interpretation of the Condominium Act that claims that an assignment of the first mortgage after the recording of an association lien results in the mortgage losing its priority, Greenbrooke vs. Hubble & Midfirst Bank, Oakland County No. 12-2005 (11-2-05). This claim was based on the assertion that an assignment was a “conveyance” of an interest in the unit, thus triggering section 211 (MCL 559.211), which requires a fee payoff request to the association.

TRANSCRIPT

Page 1: Byline from Charlie Hahn: Condominium Law Update, Legal League Quarterly | Spring 2013

10 Legal League Quarterly

States: Michigan

Condominium Law Update Get up to speed with Michigan’s latest condo rules and regs. By: Charlie Hahn, Trott & Trott

It appears that the continued legal wrangling in Michigan between mortgage servicers and condominium associations may be coming to an end. Ever since a controversial trial court decision in 2005, the Condominium Bar has been promoting an interpretation of the Con-dominium Act that claims that an assignment of the first mortgage after the recording of an association lien results in the mortgage losing its priority, Greenbrooke vs. Hubble & Midfirst Bank, Oakland County No. 12-2005 (11-2-05). This claim was based on the assertion that an assignment was a “conveyance” of an interest in the unit, thus triggering section 211 (MCL 559.211), which requires a fee payoff request to the association. Those who disputed this conclu-sion pointed out that such an interpretation ignores (or at least contradicts) clearly stated language found in other relevant provisions of the act, most notably Sections 211 and 158.

The intended effects of this theory were clear: to disrupt the foreclosure of the first mort-

gage by causing it to fail to extinguish the junior condominium lien and subsequently subjecting the mortgagee to all past unpaid assessments, late fees, and condominium attorney fees. Unfortunately, this seemingly tenuous legal theory was given additional creditability by the decision of most title insurers to refuse to insure over the junior condominium lien when the first mortgage was foreclosed. This unresolved legal tension led to a number of trial court battles. Despite the fact that a significant majority of the decisions found in favor of the assignee of the first mortgage maintaining its priority posi-tion, the litigious back-and-forth continued.

After years of debate, the issue was heard by the Court of Appeals on October 10, 2012, and a published decision was issued on Oc-tober 25, 2012, Coventry Parkhomes Condo-minium Assoc. vs. Federal National Mortgage Association, _____ Mich. App._____, No. 304188 (10-25-2012); reconsideration denied 12-18-12. The Court of Appeals did not agree

with the association and upheld normal “race-notice” principles. The strongly worded deci-sion states that there is nothing in the Condo-minium Act that could/should be interpreted to change the longstanding principal that an assignee stands in the shoes of the assignor. During oral arguments, the court displayed little sympathy for the association’s arguments, going so far as to make it clear that, in the opin-ion of the court, such an idea could inject an element of chaos into the mortgage market.

While this decision resolves what has been a nagging problem for the mortgage industry—and, in the process, promises to eliminate hundreds of thousands of dollars in improper association charges— other issues continue to generate similar discussion and debate. One of the most noteworthy of these is the issue of precisely when a sheriff ’s deed vests its title. While that question has been consistently answered by dozens of published opinions over the century and a half (and was recently restated in In re Receivership of 11910 South Franklin Rd. 492 Mich. 208, 821 NW2d 503 (7-30-12)), some members of the Condominium Bar continue to argue otherwise.

Charles L. Hahn serves as a senior litigation attorney for Trott & Trott, P.C., one of the nation’s premier law firms conducting residential default procedures and applying foreclosure avoidance solution. Contact Hahn at [email protected].

2. In a series of related cases involving sev-eral mortgages encumbering numerous invest-ment properties, a lender seized rents under the assignment of rents and leases in the mortgages. The borrowers interfered and threatened at least one tenant, so a Petition for Preliminary Injunc-tion was filed, which was granted by agreement of the parties. Despite the Injunction to which the borrowers had consented and which required that rent be turned over to the lender, the bor-rowers continued to interfere with rent flow and pocket the rent. It took two subsequent petitions (both seeking sanctions) and several evidentiary hearings for the Motions judge to issue an Order finding the borrowers in contempt of court; awarding attorneys’ fees to the lender; ordering the turnover of improperly withheld rents; and imposing a per diem interest penalty. Notwith-standing that Order, the borrowers (consistent with prior actions) did not comply. Consequently, the lender filed a fourth petition, seeking a bench warrant. Though a bench warrant was not issued, the Motions judge expressed his annoyance and dissatisfaction with the borrowers on the record at an evidentiary hearing and issued an Order giving the borrowers 30 more days to comply with his nearly nine-month-old contempt Order. Around the last day, the borrowers finally paid the monetary sanctions, but not the interest pen-alty required by the contempt Order. Addition-ally, during the course of those cases, one of the borrowers filed a Chapter 13 bankruptcy, which was frivolous. Not only did Debtor’s Schedules contain misrepresentations, but subsequent filings were not completely truthful. On the lend-er’s Rule 11/9011 motion for sanctions, relying primarily on Section 105(a) of the Bankruptcy Code, and after a hearing on the merits involving the Chapter 13 trustee, the bankruptcy judge, inter alia, barred the debtor from re-filing for six months. Though the lender had the right to also file a Petition for Appointment of Receiver, the

lender opted not to do so at the time of referral. It is believed that appointment of a receiver would not have changed the borrowers’ conduct and a receiver would have experienced the same chicanery. However, a significant advantage to a receiver is that it becomes the receiver’s responsibility, not the lender/servicer’s, to handle property management. The lender/servicer would still likely have the headache of paying for a receiver and, thus, the lender/servicer should just assume the worst when authorizing a Petition for Appointment of Receiver: That even if the receivership Order directs borrowers to pay for a receiver, they are not going to comply.

3. In a post-sheriff ’s deed ejectment (evic-tion) case, the borrowers filed a motion to stay lockout, falsely claiming that a lockout occurred. The hearing was continued three times and, each time, the borrowers raised different theories as to why lockout should be stayed. At the third hearing, the borrowers claimed that the loan had been satisfied before sheriff ’s sale by the borrow-ers’ aunt right before she had died. Despite the lender’s argument that such a claim should have been raised in the foreclosure action and not in a subsequent ejectment action, the Motions judge continued the third hearing for the borrowers to assemble and submit evidence of the payoff. At the fourth hearing, only one of the borrowers appeared and he attempted to outright avoid dis-cussing the issue of the payoff. When pressed by the Motions judge, the borrower finally conceded that there never was a payoff. Upon request of the lender’s counsel for a provision in the Court’s Order barring both borrowers from filing any further motions or petitions to postpone or stay lockout, the Motions judge initially declined from including such bar; however, the borrower con-tinued to spar verbally with the judge and never apologized for misrepresenting a material fact to him. This not only angered the Motions judge, resulting in a public on-the-record admonish-

ment that the borrowers had “wasted his time,” but also caused the Motions judge to reverse his thinking, as he ended up including the re-filing bar. The Motions judge also warned the borrower on the record that any further motions or peti-tions would result in more severe sanctions.

Therefore, under the right set of facts, lenders/servicers can obtain at least a verbal reprimand or, at best, sanctions (monetary or otherwise) for unlawful and/or inappropriate con-duct in a civil case. Sanctions, in particular, can require several motions or petitions and hearings (and are likely appealable in many jurisdictions).

However, persistence, an aggressive ap-proach, and reliance on local counsel’s expertise as to when you should fight the good fight can result in tactical advantages, such as:

» favorable court orders that serve as precedent;

» heightened settlement leverage;» re-filing bars that can preclude the

filing of further dilatory motions and/or petitions, which cost time and money to defend; and

» a message to borrowers, judges, and the defense bar that lenders/servicers are not afraid to be vigilant and willing to enforce their rights in the face of bad conduct.

In fact, the last point above is especially important, as there are individuals in the judi-ciary and defense bar who believe that lenders/servicers will generally just turn a blind eye to misbehavior in order to minimize attorneys’ fees, court costs, and headline risks. However, by not taking any action or counteraction, lenders/servicers arguably become enablers to bad apple borrowers and engender a culture of misbehavior.

Thus, we should not be completely shocked when borrowers, with or without counsel, intentionally run afoul of the law and push the envelope to see what they can “get away with.”

“Borrowers Behaving Badly” continued from page 1

Page 2: Byline from Charlie Hahn: Condominium Law Update, Legal League Quarterly | Spring 2013

14 Legal League Quarterly

THE MISSION OF THE LEGAL LEAGUE 100 IS TO PROVIDE A COMMUNICATION PLATFORM FOR INFORMATION EXCHANGE WHILE FACILITATING STRATEGIC BUSINESS-RELATIONSHIP DEVELOPMENT OPPORTUNITIES TO ITS MEMBERS AND THE MORTGAGE SERVICING COMMUNITY.

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ALABAMADumas & McPhail, LLC www.dumasmcphail.com

Jauregui & Lindsey, LLCwww.jandllawfi rm.com

McCalla Raymer, LLCwww.mccallaraymer.com

ARIZONAHouser & Allison, APCwww.houser-law.com

Law Offi ces of Les Zievewww.zievelaw.com

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CALIFORNIABarrett Daffi n Frappier Treder & Weiss, LLP626.915.5714

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Pite Duncan, LLPwww.piteduncan.com

Rosenthal, Withem and Zeffwww.rosenthalzeff.com

COLORADOAronowitz & Mecklenburg, LLP303.813.1177

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Witherspoon Law Offi ces www.witherspoonlawoffi ces.com

FLORIDAChoice Legal Group, P.A. www.marshallwatson.com

Gilbert Garcia Group, P.A.813.638.8920

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Van Ness Law Firm, P.A. www.vanlawfl .com

GEORGIAMorris Hardwick Schneider www.closingsource.net

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Rubin Lublin, LLC www.rubinlublin.com

ILLINOISCodilis & Associates, P.C. www.codilis.com

Freedman Anselmo & Lindberg, LLC www.falrlaw.com

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Unterberg & Associates, P.C. 219.736.5579

HAWAIIThe Mortgage Law Firm858.740.0442

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KENTUCKYChristopher M. Hill & Associates, PSCwww.hillslaw.com

Lerner, Sampson & Rothfusswww.lsrlaw.com

Nielson & Sherry, PSCwww.nsattorneys.com

LOUISIANADean Morris, LLP318.388.1440

MARYLANDCovahey, Boozer, Devan & Dore, P.A.443.541.8600

Rosenberg & Associates, LLCwww.rosenberg-assoc.com

The Fisher Law Group, PLLCwww.fi rst-legal.com

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Marinosci Law Group, P.C.www.mlg-defaultlaw.com

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Potestivo & Associates, P.C. www.potestivolaw.com

Schneiderman & Sherman, P.C. www.sspclegal.com

Trott & Trott, P.C.www.trottlaw.com

MINNESOTAShapiro & Zielke, LLP www.zielkeattorneys.com

Wilford, Geske & Cook, P.A. www.wgcmn.com

MISSISSIPPIAdams & Edens, P.A. *www.aelawyers.com

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Martin, Leigh, Laws & Fritzlen, P.C. www.mllfpc.com

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South & Associates, P.C. www.southlaw.com

NEBRASKAEric H. Lindquist, P.C., LLO www.elindquistlaw.com

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Kozeny, McCubbin & Katz, LLPwww.katz-law.com

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Stein, Wiener & Roth, LLP 516.742.6161

NORTH CAROLINAHutchens, Senter, Kellam & Pettit, P.A.www.hsbfi rm.com

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Weltman, Weinberg & Reis Co., LPA www.realestatedefaultgroup.com

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FO R M O RE INFO R M ATIO N AB OUT OUR MEM B ER S , C ALL 8 0 0 .856 .8 0 60 .

Page 3: Byline from Charlie Hahn: Condominium Law Update, Legal League Quarterly | Spring 2013

Legal League Quarterly 15

LEGAL LEAGUE 100 ASSOCIATE MEMBERS

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us real estate services (usres)25520 Commercentre Drive, 2nd FloorLake Forest, CA 92630949.598.9920www.usres.comCONTACT

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Page 4: Byline from Charlie Hahn: Condominium Law Update, Legal League Quarterly | Spring 2013

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