JPMorgan Chase Bank, N.A. v. Erlandson
Court of Appeals of Minnesota
821 N.W.2d 600 (2012)
Trevor and Melissa Erlandson (defendants) took out a loan from Homecomings Financial, LLC (Homecomings) in exchange for a promissory note secured by a mortgage. Legal title to the mortgage was assigned to JPMorgan Bank, N.A. (Chase) (plaintiff). The underlying promissory note was not formally assigned to Chase. The Erlandsons defaulted, and Chase sued for judicial foreclosure. The district court granted summary judgment to Chase. Chase then purchased the property at a sheriff’s sale and waived any right to a deficiency judgment. Upon Chase’s motion, the district court confirmed the sale. The Erlandsons appealed, arguing that Chase could not foreclose on the mortgage because it did not possess the underlying promissory note.
Rule of Law
Holding and Reasoning (Hooten, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 174,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.