JPMorgan Chase Bank, National Association v. Syed

231 A.3d 286 (2020)

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JPMorgan Chase Bank, National Association v. Syed

Connecticut Court of Appeals
231 A.3d 286 (2020)

Facts

Sonia Syed (defendant) obtained a loan from Washington Mutual Bank, FA (WaMu). The loan was evidenced by a note and was secured by a mortgage against Syed’s property. WaMu purportedly endorsed Syed’s note in blank (thus making the note payable to its bearer) via the signature stamp of Cynthia Riley. However, Riley was no longer employed by WaMu when someone applied Riley’s stamp to the note. After the Federal Deposit Insurance Company (FDIC) became WaMu’s receiver, JP Morgan Chase, National Association (Chase) (plaintiff), the FDIC’s attorney-in-fact, assigned Syed’s note and mortgage to itself. In May 2013, Chase sued to foreclose on Syed’s mortgage. In January 2014, Chase assigned the note and mortgage to the Christiana Trust (Christiana) (plaintiff), which was substituted as the plaintiff in December. In January 2016, Christiana moved for summary judgment. Syed opposed Christiana’s motion, arguing that Chase never owned her note and thus could not have conveyed the note to Christiana because the purported endorsement using the name and signature stamp of a former WaMu employee was invalid. Christiana responded that the endorsement was valid under Connecticut’s version of Uniform Commercial Code (UCC) § 3-401(b). The trial court ruled against Syed and ordered a strict foreclosure in favor of the Wilmington Savings Fund Society, FSB (Wilmington) (plaintiff), to which Christiana had assigned the note in the interim. Syed appealed, reasserting her argument that the purported WaMu endorsement was invalid.

Rule of Law

Issue

Holding and Reasoning (Bright, J.)

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