Mortgage Resolution Servicing, LLC v. JPMorgan Chase Bank, N.A.

Background

Plaintiffs Mortgage Resolution Servicing, LLC, 1st Fidelity Loan Servicing, LLC, and S&A Capital Partners, Inc. moved for partial reconsideration of the court’s September 27, 2019, memorandum opinion and order. That earlier order granted, in relevant part, summary judgment—a decision that resolves claims when the evidence shows there is no genuine dispute requiring a trial—for Defendants JPMorgan Chase Bank, N.A., JPMorgan Chase & Co., and Chase Home Finance, LLC.

The earlier order dismissed Plaintiffs’ breach-of-contract claims based on alleged breaches occurring on or after December 24, 2009. The court had found that Plaintiffs did not provide sufficient proof of damages to create a genuine issue of material fact, did not establish the legal viability of certain damages theories, and could not satisfy their summary-judgment burden by promising to present damages evidence later through trial testimony.

Plaintiffs’ Motion

Plaintiffs argued that the court had overlooked evidence that could support a finding of damages. They also argued that the earlier decision was clearly erroneous and that leaving it unchanged would cause manifest injustice, meaning serious unfairness. Plaintiffs relied in part on an assertion that lien releases and debt-forgiveness letters sent by Chase had interfered with more than $16 million in secured debt after March 1, 2012. In the reconsideration motion, Plaintiffs characterized the issue as Chase’s actions eliminating $16 million in recoverable loan equity.

Court’s Analysis

The court explained that reconsideration is an extraordinary remedy used sparingly. It may be justified by an intervening change in controlling law, newly available evidence, a clear legal error, or the need to prevent manifest injustice. It is not a way to relitigate old issues, present new theories, obtain another hearing on the merits, or take a second opportunity to argue the case.

The court found that Plaintiffs did not provide additional admissible evidence correcting the deficiencies identified in the September order. They also did not identify a clear error or show that refusing reconsideration would cause manifest injustice. Instead, the motion primarily repeated arguments made during the summary-judgment proceedings.

The court specifically found that Plaintiffs cited nothing supporting a reasonable conclusion that the alleged $16 million in benefits Chase received from the United States government corresponded to recoverable loan equity. The court concluded that Plaintiffs’ unsupported recharacterization of their earlier arguments was insufficient for reconsideration.

Disposition

Judge Laura Taylor Swain denied Plaintiffs’ motion for reconsideration. The order states that the ruling resolves docket entries 430 and 431.