Eagle Equity Fund v. TitleOne Corp

This case arose from an allegedly improper reconveyance of a junior deed of trust (the “EEF Deed of Trust”) held by Appellant, Eagle Equity Fund, LLC (“EEF”). The reconveyance, which was executed by Respondent, TitleOne Corporation, had the effect of divesting EEF of its security interest in the collateral property. Because EEF was divested of its security interest, it did not receive notice when the Property was later sold to DAS Investments, LLC. Being unaware of the sale, EEF had no opportunity to participate in the sale process. Shortly thereafter, DAS resold the Property to Corey Barton Homes, Inc. (“CBH”), for a profit. On discovering the sale and resale of the Property, EEF sued TitleOne, DAS, and CBH, among others, on a litany of counts including tortious interference and negligent reconveyance of the EEF Deed of Trust. On appeal, EEF argued that: (1) the reconveyance damaged EEF by depriving it of the opportunity to insert itself into the sale of the Property; (2) the statute of limitations had not run on EEF’s negligent reconveyance claim under Idaho Code section 45-1205 because it should have been calculated from the date of the sale rather than from the date of the reconveyance; and (3) DAS and CBH were not bona fide purchasers because they had inquiry notice of EEF’s interest. After review, the Supreme Court concluded: (1) EEF had no claim against TitleOne for tortious interference with a prospective economic advantage, so the district court did not err in dismissing EEF's claims against TitleOne on summary judgment; (2) because the district court did not err in so granting summary judgment, the Supreme Court did not reach EEF's contention that the district court miscalculated the statute of limitations; and (3) the district court did not abuse its discretion in refusing t allow EEF to amend its complaint to add a quiet title claim against CBH. Accordingly, the Court affirmed the district court's judgment. View "Eagle Equity Fund v. TitleOne Corp" on Justia Law