CourtListener 10124030•Kevin F. MacDonald v. Jp Morgan Chase Bank, N.A.
Kevin F. MacDonald v. Jp Morgan Chase Bank, N.A.
CourtListener 10124030Massappct23 set 2024
Testo completo
NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule
23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28,
as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties
and, therefore, may not fully address the facts of the case or the panel's
decisional rationale. Moreover, such decisions are not circulated to the entire
court and, therefore, represent only the views of the panel that decided the case.
A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25,
2008, may be cited for its persuasive value but, because of the limitations noted
above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260
n.4 (2008).
COMMONWEALTH OF MASSACHUSETTS
APPEALS COURT
23-P-687
KEVIN F. MACDONALD
vs.
JP MORGAN CHASE BANK, N.A.
MEMORANDUM AND ORDER PURSUANT TO RULE 23.0
The plaintiff appeals from a Superior Court judge's entry
of summary judgment in favor of the defendant on the plaintiff's
claims stemming from the defendant's foreclosure on and sale of
a home owned by the estate of the plaintiff's mother. The
plaintiff's complaint alleged that the foreclosure sale was not
noticed properly and must be rescinded and that the foreclosure
sale was unlawful because the plaintiff had adversely possessed
portions of the property. The judge dismissed the complaint,
ruling that the plaintiff had no standing to bring the action.
We affirm.
Background. In 2005, the plaintiff's mother granted a
mortgage on her home to the defendant bank as security for a
home equity line of credit. The plaintiff's mother died in
2013. She left a will in which she designated the plaintiff and
his brother as joint executors of her estate. A petition for
informal probate was filed in 2016, pursuant to which the
plaintiff and his brother were approved as co-personal
representatives. The will provided the plaintiff, who had lived
in his mother's home for decades, a limited-time option to
purchase the house. The plaintiff did not exercise the option.
In that event, the will provided that the house was to be sold
and any proceeds contributed to the residue of the estate, which
was to be distributed equally between the plaintiff and his
brother. The defendant initiated foreclosure proceedings in
November 2019 with notice to the plaintiff and his brother. The
plaintiff filed the instant complaint two years later in
November 2021 to stop the ensuing foreclosure sale, arguing that
he adversely possessed the property and also that the
foreclosure sale had not been properly noticed.
Discussion. On appeal, the plaintiff argues that the judge
erred as a matter of law in dismissing the suit because he had
standing both as a personal representative of his mother's
estate and individually as owner of the property by adverse
possession.
1. Standing as personal representative. A personal
representative has the authority to sue on behalf of the estate,
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G. L. c. 190B, § 3-703 (c), in furtherance of the
representative's fiduciary obligations thereto. G. L. c. 190B,
§ 703 (a). However, where there are joint personal
representatives:
"unless the will provides otherwise, the concurrence of all
is required on all acts connected with the administration
and distribution of the estate. This restriction shall not
apply . . . when the concurrence of all cannot readily be
obtained in the time reasonably available for emergency
action necessary to preserve the estate, or when a co-
representative has been delegated to act for the others."
G. L. c. 190B, § 3-717. Here, the plaintiff brought the action
alone without the co-personal representative. He does not argue
that he did not have time to obtain his brother's concurrence
prior to filing suit. Rather, he argues that his brother was in
favor of the foreclosure going forward and did not consent to
the lawsuit. Yet, the plaintiff contends that he falls within
the exception to the "concurrence of all" requirement because
the situation called for "emergency action necessary to preserve
the estate."
Although these terms appear not to have been previously
construed in the case law, a plain reading of the statute shows
that the exception to "concurrence of all" is triggered when
consent "cannot readily be obtained in the time reasonably
available for emergency action." G. L. c. 190B, § 3-717. See
Mack v. District Attorney for the Bristol Dist., 494 Mass. 1, 12
(2024) (statutory interpretation begins with plain language of
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statute). Here, the plaintiff had ample time, at least two
years since foreclosure proceedings began, to obtain his
brother's consent. Nor can the lawsuit filed on the eve of the
foreclosure sale be considered "emergency action" necessary to
preserve the estate, given the lengthy notice of foreclosure
proceedings. See Black's Law Dictionary 660 (11th ed. 2019)
(emergency is "sudden and serious event or an unforeseen change
in circumstances that calls for immediate action to avert,
control, or remedy harm").
The plaintiff's view that his brother's refusal to concur
justified his unilateral action cannot be sustained. Such an
interpretation would have the exception swallow the rule. See
Adoption of Daphne, 484 Mass. 421, 424 (2020) (statute must be
interpreted according to intent of Legislature so as to render
law effective, consonant with sound reason and common sense).
Personal representatives act as fiduciaries. G. L. c. 190B,
§ 3-703 (a). As such, they are required to act prudently and
reasonably to preserve the estate's value for the beneficiaries.
See Taylor v. Jones, 242 Mass. 210, 215, cert. denied, 260 U.S.
742 (1922). The "emergency action" exception to the usual
requirement that co-personal representatives act together
safeguards this principle by freeing co-personal representatives
from having to obtain permission when swift action is sensible
and necessary. By contrast, allowing personal representatives
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to circumvent longstanding differences of opinion by claiming
the unilateral right to act on behalf of the estate would
undermine the statute's central purpose of requiring
concurrence. We conclude that the plaintiff did not fall within
the exception allowing unilateral action. As a result, he did
not have standing to bring suit on behalf of the estate.
2. Standing as owner by adverse possession. To establish
that he adversely possessed his mother's former home, the
plaintiff was required to show "nonpermissive use which is
actual, open, notorious, exclusive and adverse for twenty
years." Lawrence v. Concord, 439 Mass. 416, 421 (2003), quoting
Kendall v. Selvaggio, 413 Mass. 619, 621-622 (1992). "The
burden of proving adverse possession is on the person claiming
title thereby and 'extends to all of the necessary elements of
such possession.'" Id., quoting Mendonca v. Cities Serv. Oil
Co. of Pa., 354 Mass. 323, 326 (1968). "[T]he purpose of the
various requirements of adverse possession . . . is to put [the
owner] on notice of the hostile activity of the possession so
that he, the owner, may have an opportunity to take steps to
vindicate his rights by legal action." Air Plum Island, Inc. v.
Society for the Preservation of New England Antiquities, 70
Mass. App. Ct. 246, 252 (2007), quoting Ottavia v. Savarese, 338
Mass. 330, 332-333 (1959).
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Here, there are no facts in the summary judgment record
raising a material dispute whether the plaintiff exclusively
occupied the subject premises for twenty years or did so without
permission. The plaintiff claims adverse possession in his
complaint, but has mustered no evidence to show that he has met
the elements of that claim. See LaLonde v. Eissner, 405 Mass.
207, 209 (1989) ("[T]he opposing party cannot rest on his or her
pleadings and mere assertions of disputed facts to defeat the
motion for summary judgment"). In fact, the plaintiff says in
his brief that he has occupied two rooms of the home, which
suggests that his use of the property has not been exclusive.
The plaintiff failed to establish his standing as owner by
adverse possession.
Judgment affirmed.
By the Court (Singh, Hand &
D'Angelo, JJ.1),
Clerk
Entered: September 23, 2024.
1 The panelists are listed in order of seniority.
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