[WSBARP] Deed of Trust Enforceability Issues
Mark Anderson
marka at mbaesq.com
Wed Nov 6 16:19:05 PST 2024
I have reviewed a few more cases and think I now have a defensible approach to this situation.
The Note was not accelerated (had it been, that would have changed my analysis). By the express language of the Note, the final payment on the Note was due on October 1, 2019. Because the Note was not accelerated, the amount of that final payment due would include all past due amounts, including the amounts of unpaid installment payments.
The statute of limitation on this debt will run on October 1, 2025.
Please feel free to commend or challenge my conclusions here. Thanks.
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From: wsbarp-bounces at lists.wsbarppt.com <wsbarp-bounces at lists.wsbarppt.com> On Behalf Of Mark Anderson
Sent: Wednesday, November 6, 2024 3:48 PM
To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com>
Subject: Re: [WSBARP] Deed of Trust Enforceability Issues
I took a look at Copper Creek, as well as Cedar West and Merceri. Much of their discussions center around acceleration of the debt and tolling of the statute of limitations. I agree that a cause of action does accrue for each installment payment at the time it is missed and that the statute of limitation to collect that individual installment payment begins to run at that time.
However, according to the express language of the Note, as of October 1, 2019, the entire unpaid balance of the Note became due, not just individual installments. Yes, the unpaid balance was affected by not making the individual installments. At that point, then, perhaps the unpaid balance would include only those amounts that which, by that time, had not been rendered uncollectible by the statute of limitations. In any event, the amount due as of October 1, 2019, included far more than the amount of the missed installments (default interest, late fees, additional advances).
I'm trying to come up with an approach for the "proper" calculation of the amount due as of October 1, 2019. As of that date, a calculable sum certain was due. The SOL on that debt runs until October 1, 2025. Do I then subtract from that amount the total of missed installment payments that are more than 6 years old from today's date? Or would it be more than 6 years old from October 1, 2019? And what about interest that had accrued during that period on the entire debt (and not just on the amount of each missed installment payments)?
I could still use some help in finding support for Bryce Dille’s analysis. All other feedback is welcome as well.
Thanks.
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Subject: Re: [WSBARP] Deed of Trust Enforceability Issues
Mark: A Recent Supreme court opinion in Copper Creek, addressed the statute of limitations as to payments under a deed of trust. If the underlying note had language calling for installment payments (monthly, quarterly, annually etc.) then the statute of limitations runs separately (6 years) on each installment from its due date. If only one payment is due, then statute of limitations runs from the date that payment is made.
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Subject: Re: [WSBARP] Deed of Trust Enforceability Issues
The Note (form LPB 28A-05) requires the monthly payment of principal and interest installments. But then it does go on to read,
"DUE DATE: The entire balance of this Note together with any and all interest accrued thereon shall be due and payable in full on the October 1, 2019 7 year term."
Are you all saying, then, that the statute of limitation began to run on October 1, 2019?
Mark B. Anderson
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From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Bryce Dille
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To: WSBA Real Property Listserv <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Deed of Trust Enforceability Issues
It depends on the language in the note if the note says the entire principal balance together with accrued interest must be paid on or before a certain date even though it is an installment note then the final installment is whatever hasn't been paid up to that date and therefore the statute of limitations would run on that date however if the installment note simply said X dollars a month at a certain rate of interest until paid in full then I would agree the statute of limitations begins to run on each installment under the note and all you can collect are those installments that haven't been paid within the statute of limitations period.
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Subject: Re: [WSBARP] Deed of Trust Enforceability Issues
Read it. Doesn’t appear to overrule Herzog:
¶21 Applying the principles outlined above to this case, the six-year statute of limitations on each individual missed installment payment began to run on the due date of each missed payment. Thus, there are some individual installment payments that may now be barred by the six-year statute of limitations. But the final statute of limitations has not yet begun to run on any of the notes or deeds of trust. That final statute of limitation will not begin to run on any note or its corresponding deed of trust until that note reaches maturity. Wash. Fed., 195 Wash. App. at 663, 382 P.3d 20<https://urldefense.proofpoint.com/v2/url?u=https-3A__scholar.google.com_scholar-5Fcase-3Fcase-3D15542112841248524962-26q-3DSee-2BMerritt-2Bv.-2BUSAA-2BFederal-2BSavings-2BBank-26hl-3Den-26as-5Fsdt-3D4-2C48&d=DwMFaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=ZjJT61sMYHYXW1a7W0qvaz-zO3o_Ea2RRxXvW5Yr3-0&m=vSs1q2sbKwNS_ejX5tADoybAxenkCbm-gQWGvb6-1_8RwQa4PELZ68mZhhsVBVvc&s=uedoKt0oU1c0SoX9YB1CB2eqRyJdZwzauJJ2w_wr4ek&e=> (citing Hopper v. Hemphill, 19 Wash. App. 334, 335-36, 575 P.2d 746 (1978)<https://urldefense.proofpoint.com/v2/url?u=https-3A__scholar.google.com_scholar-5Fcase-3Fcase-3D6381401726308915942-26q-3DSee-2BMerritt-2Bv.-2BUSAA-2BFederal-2BSavings-2BBank-26hl-3Den-26as-5Fsdt-3D4-2C48&d=DwMFaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=ZjJT61sMYHYXW1a7W0qvaz-zO3o_Ea2RRxXvW5Yr3-0&m=vSs1q2sbKwNS_ejX5tADoybAxenkCbm-gQWGvb6-1_8RwQa4PELZ68mZhhsVBVvc&s=5YjX3RoTOFNpKpGwuLyvwtbHeAj9QDxf0FRpuBJS3Bk&e=>; Westar Funding, 157 Wash. App. at 784, 239 P.3d 1109<https://urldefense.proofpoint.com/v2/url?u=https-3A__scholar.google.com_scholar-5Fcase-3Fcase-3D12471014541614950616-26q-3DSee-2BMerritt-2Bv.-2BUSAA-2BFederal-2BSavings-2BBank-26hl-3Den-26as-5Fsdt-3D4-2C48&d=DwMFaQ&c=euGZstcaTDllvimEN8b7jXrwqOf-v5A_CdpgnVfiiMM&r=ZjJT61sMYHYXW1a7W0qvaz-zO3o_Ea2RRxXvW5Yr3-0&m=vSs1q2sbKwNS_ejX5tADoybAxenkCbm-gQWGvb6-1_8RwQa4PELZ68mZhhsVBVvc&s=i_rIZU39FfNSk-xuk9ly2FPBrNdq4jE69-J9zIy0h7k&e=>; 31 WILLISTON & LORD, supra, § 79:17, at 338, § 79:18, at 347-50).
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From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> [mailto:wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>] On Behalf Of Randy Boyer
Sent: Wednesday, November 6, 2024 9:28 AM
To: Real Property Listserve
Subject: Re: [WSBARP] Deed of Trust Enforceability Issues
See Merritt v. USAA Federal Savings Bank
Randy M. Boyer ______
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On Nov 6, 2024, at 7:28 AM, Mark McClure <mark at mcclurelawgroup.com<mailto:mark at mcclurelawgroup.com>> wrote:
Hi Randy,
Wouldn’t only the portion due and owing within the 6 years prior to the commencement of the case be the only thing that could be sued on, not the entire balance? Is it still worth it in this case?
"[w]hen Statute of Limitations begins to run against an action to recover upon contract payable in instal[l]ments" and describes the general rule: "The general rule in such a case is similar to the general rule herewith noted in the case of contract obligations, it having been held that the Statute of Limitations begins to run from the expiration of the period fixed for the payment of each instal[l]ment as it becomes due, for the part then payable."
See Herzog v. Herzog, 23 Wn.2d 382, 388, 161 P.2d 142 (1945).
Mark C. McClure
Managing Attorney
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"Why Retire With Debt?"
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From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> [mailto:wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>] On Behalf Of Mark Anderson
Sent: Tuesday, November 5, 2024 5:08 PM
To: WSBA Real Property Listserv
Subject: Re: [WSBARP] Deed of Trust Enforceability Issues
Thanks for weighing in, Randy. I wanted to see what was enforceable and what was not.
Mark B. Anderson
ANDERSON LAW FIRM PLLC
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Tacoma, Washington 98402
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From: wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com> <wsbarp-bounces at lists.wsbarppt.com<mailto:wsbarp-bounces at lists.wsbarppt.com>> On Behalf Of Randy Boyer
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To: Real Property Listserve <wsbarp at lists.wsbarppt.com<mailto:wsbarp at lists.wsbarppt.com>>
Subject: Re: [WSBARP] Deed of Trust Enforceability Issues
Mark,
Case law holds that the SOL continues as long as payments are due. The final payment was due in 2019. So Seller has 6 years after the date that payment was due. A Judicial foreclosure should be initiated right away.
Randy M. Boyer ______
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On Nov 5, 2024, at 1:08 PM, Mark Anderson <marka at mbaesq.com<mailto:marka at mbaesq.com>> wrote:
Dear All:
I could use your help with a scenario I have not seen before.
August 2012 – Owner purchased property from Seller. Owner gave Seller a Note secured by a DOT on the property. Note was payable over 7 years.
August 2014 – Owner stopped making payments. Seller took no action to enforce the Note or DOT. (I know the six-year statute of limitation began to run at this point for enforcement of the principal obligation.)
September 2019 – Seller paid (advanced) property taxes on behalf of Owner to avoid a tax sale. Owner continued to not make payments. Seller again took no action to enforce the Note or DOT.
October 2024 – property is up again for a tax sale.
(Note: I have no idea why the Seller has never taken any action to enforce the note or DOT.)
Questions:
1. Did the September 2019 payment of taxes affect the statute of limitations for enforcing the DOT? If so, how?
2. Does the DOT still secure repayment of the additional amounts advanced under the Note, even if it (I think likely) does not secure repayment of the original amounts due and owing under the Note?
3. Independent of the Note and DOT, does the payment of property taxes on behalf of Owner give Seller any right to file a lien against the property in advance of the tax sale?
Thanks in advance for any answers or other insights you can provide.
Mark B. Anderson
ANDERSON LAW FIRM PLLC
821 Dock St Ste 209 PMB 4-12
Tacoma, Washington 98402
+1 253-327-1750
+1 253-327-1751 (fax)
marka at mbaesq.com<mailto:marka at mbaesq.com>
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