Quimbee logo
DMCA.com Protection Status
From our private database of 16,500+ case briefs...

Warren v. Government National Mortgage Association

United States Court of Appeals for the Eighth Circuit
611 F.2d 1229 (1980)


Warren (plaintiff) purchased a home in Missouri from the United States Department of Housing and Urban Development (HUD), subject to a mortgage held by Government National Mortgage Association (GNMA) (defendant). GNMA was a private corporation but was wholly-owned by the federal government. GNMA was managed by HUD and its mortgages were insured by the Federal Housing Authority (FHA). Warren’s mortgage was secured by a deed of trust, which permitted GNMA, in the event of a default, to foreclose on the property under Missouri law. Warren defaulted on the mortgage. GNMA commenced foreclosure proceedings and ultimately purchased the property at a public sale. The foreclosure was conducted by a trustee that was not a government employee, pursuant to the terms of the deed of trust and Missouri foreclosure law. Warren brought suit against GNMA, claiming that the foreclosure sale violated her Fifth Amendment due process rights. The trial court found that the foreclosure did not invoke the Fifth Amendment because there was no federal action. Warren appealed.

Rule of Law


Holding and Reasoning (McManus, J.)

Concurrence (Ross, 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 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.

  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 400,000 law students have relied on our case briefs:

  • Written by law professors and practitioners, not other law students. 16,500 briefs, keyed to 223 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