Quimbee logo
DMCA.com Protection Status
  • P
  • PHH Mortgage Corp. v. RamseyPHH Mortgage Corp. v. Ramsey
From our private database of 16,800+ case briefs...

PHH Mortgage Corp. v. Ramsey

Ohio Court of Appeals
17 N.E.3d 629 (2014)


Andrew Ramsey (defendant) purchased real property subject to a mortgage held by PHH Mortgage Corporation (PHH) (plaintiff). Ramsey made mortgage payments online through PHH’s website for six years. PHH permitted and, in fact, encouraged its mortgagors to make payments online. Ramsey occasionally received error messages when he attempted to make his payments online. When this occurred, Ramsey would simply try again at a later date, and the payment would process on a subsequent attempt. PHH never rejected a payment Ramsey made this way. In August 2009, Ramsey tried to make his monthly payment online and received the error message he would occasionally see. This time, however, the payment did not process after multiple subsequent attempts. Ramsey called a PHH help line to describe the issue and was told that the payment would be processed. However, the payment was never processed. The September 2009 payment also went unprocessed, despite Ramsey attempting to make the payments both online and in person at a PHH office. Ramsey had also mailed to PHH a check for the late August payment with a letter explaining the situation. This attempted payment was never cashed or returned. PHH filed a complaint foreclosing on the property. PHH argued that although it allowed electronic payments, this payment method was not a mortgagor’s right. The Franklin County Court of Common Pleas held in favor of Ramsey, finding that Ramsey did not default on his mortgage, because PHH had accepted Ramsey’s electronic payments for six years, and thus, had waived any claim that payment could not be made electronically. PHH appealed.

Rule of Law


Holding and Reasoning (Brown, J.)

What to do next…

  1. 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 449,000 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.

  2. 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 449,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 16,800 briefs, keyed to 224 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.

Questions & Answers

Have a question about this case?

Sign up for a free 7-day trial and ask it

Sign up for a FREE 7-day trial