Coker v. JPMorgan Chase Bank, N.A.

62 Cal. 4th 667, 364 P.3d 176 (2016)

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Coker v. JPMorgan Chase Bank, N.A.

California Supreme Court
62 Cal. 4th 667, 364 P.3d 176 (2016)

Facts

In 2004, Carol Coker (plaintiff) borrowed $425,000 from Valley Vista Mortgage Corporation (Valley Vista) to finance her purchase of a condominium. The loan was secured by a deed of trust recorded against Coker’s condominium. Valley Vista subsequently sold the loan to JP Morgan Chase Bank, N.A. (Chase) (defendant). Several years later, Coker fell behind on her payments, and Chase notified her that she was in default. As Chase began foreclosure proceedings, Coker found a purchaser who was willing to pay $400,000 for the condominium. The proceeds of the sale would be less than Coker’s remaining loan balance, so Coker asked Chase to allow a short sale of the property. Chase approved the short sale, which required Coker to give Chase all of the proceeds from the sale in exchange for Chase’s release of its lien on the condominium. After receiving the proceeds of the short sale, Chase demanded that Coker pay the remaining loan balance, which totaled $116,687. Coker filed a declaratory-judgment action claiming that California law prohibited Chase from collecting the deficiency. The trial court granted Chase’s motion to dismiss, and the intermediate appellate court reversed. Chase appealed to the California Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Liu, J.)

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