AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Deutsche Bank sought to foreclose on the Slades' mortgage, alleging ownership and holder status of the note and mortgage originally with New Century Mortgage Corporation. The Slades did not raise standing, jurisdiction, or affirmative defenses in their pro se answer. Despite no written response from the Slades to Deutsche Bank's motion for summary judgment, the district court entered a decree of foreclosure, which was followed by a sale of the mortgaged property. Nearly two years post-sale, the Slades moved to set aside the judgment as void, citing a Supreme Court opinion on standing in foreclosure cases (paras 2-4).

Procedural History

• District Court, January 9, 2009: Entered a stipulated summary and default judgment, decree of foreclosure, and appointment of special master in favor of Deutsche Bank (para 3).
• District Court, June 2012: Entered an order confirming the sale of the mortgaged property (para 3).
• District Court, April 7, 2014: The Slades filed a motion to set aside the judgment as void, based on standing issues (para 4).

Parties' Submissions

• Plaintiff-Appellant (Deutsche Bank): Argued that the note and mortgage were assigned to it, making it the owner and holder in due course, and sought foreclosure on the Slades' mortgage (para 2).
• Defendants-Appellees (the Slades): Filed a motion to set aside the foreclosure judgment as void, arguing lack of standing by Deutsche Bank based on a Supreme Court opinion (para 4).

Legal Issues

• Whether the district court erred in dismissing Deutsche Bank's foreclosure complaint and voiding the decree of foreclosure for lack of standing (para 1).
• Whether a final judgment on a mortgage foreclosure action is voidable under Rule 1-060(B) due to a lack of prudential standing (para 6).

Disposition

• The Court of Appeals reversed the district court's decision, dismissing Deutsche Bank’s foreclosure complaint as void for lack of standing (para 8).

Reasons

• The Court of Appeals, with Chief Judge Linda M. Vanzi and Judges Jonathan B. Sutin and Henry M. Bohnhoff concurring, found that the district court erred in dismissing the foreclosure complaint for lack of standing. The appellate court referenced the Supreme Court's clarification in Deutsche Bank National Trust Co. v. Johnston that standing in mortgage foreclosure cases is prudential, not jurisdictional, and cannot be challenged after a trial on the merits. Since the Slades attempted to void the final judgment based on standing—a move expressly prohibited by the Supreme Court—their motion under Rule 1-060(B) had no legal basis. The appellate court concluded that the district court's dismissal of the foreclosure complaint and the voiding of the decree of foreclosure and subsequent sale were incorrect, leading to the reversal of the district court's decision (paras 5-8).