Traschsel v. Litton Loan Servicing, LP et al
Filing
84
OPINION AND ORDER - For the reasons stated, the court concludes that there are genuine issues of material fact on Trachsel's UTPA and fraud claims, and Littion Loan's motion for summary judgment 65 is DENIED. IT IS SO ORDERED. Dated this 8th day of November, 2011, by U.S. Magistrate Judge John V. Acosta. (peg)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF OREGON
PORTLAND DIVISION
MATT J. TRACHSEL,
Civ. No. 09-1053-AC
OPINION AND
ORDER
Plaintiff,
v.
LITTON LOAN SERVICING, LP, a Texas
limited partnership,
Defendant.
ACOSTA, Magistrate Judge:
introduction
Plaintiff Matt J. Trachsel ("Trachsel") has alleged claims against Litton Loan Servicing, LP
("Litton Loan") for unfair trade practices and for fraud, arising in the context of mortgage default,
modification, and foreclosure. Trachsel alleges that after he defaulted on his mortgage Litton Loan
OPINION AND ORDER
1
{KPR}
offered him an opportunity to modify his loan agreement and avoid foreclosure. Trachsel claims that
Litton Loan made misrepresentations regarding the requirements of the modification and the
pendency of the foreclosure, which misrepresentations Trachsel relied on to his detriment. Trachsel
further alleges that these misrepresentations resulted in Trachsel's property being transfe1'l'ed to
affiliates of Litton Loan. Litton Loan argues that Trachsel cannot state a claim under UTP A; that
its verbal representations to Trachsel are unenforceable; and that Trachsel's reliance on its
representations was not reasonable. For the reasons that follow, the comt concludes that there are
genuine issues of material fact as to both Trachsel's UTPA and fraud claims, and Litton Loan's
motion for summary judgment is denied.
Factual Background
On September 23,2005, Trachsel borrowed $112,000 from Fieldstone Mortgage Company
("Fieldstone") to purchase a share in the residential propelty at 1479 Fifer Road, Seaside, Oregon
("the property"). (Defendant's Concise Statement of Material Fact ("Def.'s CSMF") ~ 2.) The loan
was evidenced by a promissory note and secured by a deed of trust ("the deed") to the property,
which deed was granted to Mortgage Electronic Registration Systems ("MERS") as nominee for
Fieldstone. (Def.'s CSMF
~
2.) Stewart Title of Oregon originally acted as trustee. (Ledet
Declaration ("Decl."), Exhibit ("Ex.") 2 at 1.) Litton Loan, "a loan servicing company for HSBC[,]"
was the serviceI' of Trachsel's residential mOltgage. (Plaintiffs Response ("PI.'s Resp.") CSMF ~
S.) On July 23, 2007, MERS assigned the deed to HSBC "as Indenture Trustee of the Fieldstone
Mortgage Investment Trust, Series 2005-3." (PI.'s Resp. CSMF ~ S; Ledet Decl., Ex. 3.)
In May 200S, Trachsel defaulted on his loan and, as of June 200S, the loan was officially in
default. (Def.'s CSMF ~ 4.) On December 24, 200S, Trachsel received a "Notice of Default and
OPINION AND ORDER
2
{KPR}
Election to Sell" which set forth a foreclosure date of May 8, 2009. (P!. 's Resp. CSMF '\[9.) The
foreclosure date was confirmed by a Trustee's Notice of Sale, also sent to Trachsel, dated Januaty
2,2009. (P!.'s Resp. CSMF '\[9.) Litton Loan, via its agent Titanium Solutions, sent Trachsel a loan
modification proposal to assist Trachsel in avoiding foreclosure.
(Def. 's CSMF '\[ 6.) The
modification agreement was subject to conditions and required specific submissions by Trachse!.
(CSMF '\[6.) In particular, the loan modification documents stated that as a program requirement
that Trachsel "[s]ign the enclosed Loan Modification Agreement, have it notarized, and return it to
Litton Loan at the address provided below." (Ledet Dec!., Ex. 6 at 4.) The agreementitselfprovided
for Trachsel's signature, as well as for that of a notary public. (Ledet Dec!., Ex. 6 at 6.) Trachsel
was told, however, that notarization was not necessary. (Trachsel Dec!. '\[5.)
Trachsel returned the loan modification documents. In FebruaIY 2009, he had not heard back
from Litton Loan regarding his loan modification application and he began calling Litton Loan to
inquire as to its status. (Trachsel Dec!. '\[6.) He was repeatedly told that Litton Loan was postponing
its decision pending release of President Obama's mOligage foreclosure plan. (Trachsel Decl. '\[7.)
Trachsel was never informed that his documentation was deficient in any way. Id. The original
foreclosure date, May 8, 2009, came and went, and Trachsel was informed that the date was "open"
or "blank," and was told he would be notified in advance of any pending foreclosure. (Trachsel
Dec!. ,\[,\[7,8.) On June 29, 2009, Trachsel received a letter requesting documentation for the loan
modification, all of which he had already submitted. The letter did not mention a notarization
requirement. (Trachsel Decl. Ex. D.) Trachsel called the contact number stated on the letter to
infOlTI1 them he had already submitted the documents in question; he was not infol111ed at that time
that his documentation was otherwise deficient. (Trachsel Dec!. '\[9.)
OPINION AND ORDER
3
{KPR}
After defaulting on his loan, but prior to foreclosure, Trachsel approached his friend Teny
Lowenberg ("Lowenberg") to ask about the possibility of Lowenberg making a private loan to
Trachsel for the purpose of curing his loan default and avoiding foreclosure. (Def.' s CSMF ~ II.)
In Lowenberg's words: "I told Mr. Trachsel that if it came to foreclosure, I was willing to personally
loan him the funds to payoff his lender and to prevent his property from being foreclosed."
(Lowenberg Decl.
~
3.)
According to Trachsel, he called Litton Loan two times per month between February and
August 2009 to inquire about the status of his loan modification, though he never attempted to
communicate with Litton Loan in writing. (Trachsel Deposition 21:21-25; 23:11-19.) In a letter
dated July 28,2009, Litton Loan informed Trachsel that the modification had been denied. (P!"s
Resp. CSMF ~ 13.) The letter stated: "you have failed to properly endorse or notarize the original
Loan Modification Agreement and/or return the required funds, and the time frame to complete the
modification has expired.
If foreclosure action has begun, it will continue until you make
arrangements with us. Please call us today." (Thomas Affidavit ("Aff."), Ex. 1 at 6.) After
receiving this letter, Trachsel called Litton Loan repeatedly, but was unable to reach a representative
and, despite leaving a number of messages, his calls were not returned. (Trachsel Decl.
~
10.)
Trachsel was never notified ofthe new foreclosure date. (Trachsel Dec!. ~ 11.) On August 7, 2009,
the property was sold at foreclosure sale. (P!.'s Resp. CSMF
~
15.) Trachsel's property was
purchased by Quality Loan Service Corp. of Washington ("Quality Loan"). (Def.'s Request for
Judicial Notice, Ex. 5 at 1.) Trachsel believes that both Quality Loan and Fieldstone are affiliated
with Litton Loan and participated in the fraud. (Comp!.
OPINION AND ORDER
4
~14.)
{KPR}
Standard
Summmy judgment is appropriate "ifthe movant shows that there is no genuine dispute as
to any material fact and the movant is entitled to judgment as a matter oflaw." FED. R. ClY. P. 56(a)
(2011). Summmy judgment is not proper if material factual issues exist for trial. Warren v. City of
Carlsbad, 58 FJd 439, 441 (9th Cir. 1995).
The moving party has the burden of establishing the absence of a genuine issue of material
fact. Celotex Corp. v. Catrett, 477 U.S. 317,323 (1986). Ifthe moving party shows the absence of
a genuine issue ofmaterial fact, the nonmoving party must go beyond the pleadings and identify facts
which show a genuine issue for trial. Id. at 324. A nonmoving party cannot defeat summary
judgment by relying on the allegations in the complaint, or with unsupported conjecture or
conclusory statements. Hernandez v. Spacelabs Medical, Inc., 343 FJd 1107,1112 (9th Cir. 2003).
Thus, summmy judgment should be entered against "a party who fails to make a showing sufficient
to establish the existence of an element essential to that party's case, and on which that party will
bear the burden of proof at trial." Celotex, 477 U.S. at 322.
The comt must view the evidence in the light most favorable to the nomnoving party. Bell
v. Cameron Meadows Land Co., 669 F.2d 1278, 1284 (9th Cir. 1982). All reasonable doubt as to
the existence of a genuine issue of fact should be resolved against the moving party. Hector v.
Wiens, 533 F.2d 429, 432 (9th Cir. 1976). However, deference to the nomnoving pmty has limits.
The nonmoving party must set forth "specific facts showing age/llIine issue for trial." FED. R. ClY.
P. 56(e) (2008) (emphasis added). The "mere existence of a scintilla of evidence in support of the
plaintiffs position [is] insufficient." Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 252 (1986).
Therefore, where "the record taken as a whole could not lead a rational trier of fact to find for the
OPINION AND ORDER
5
{KPR}
nonmoving party, there is no genuine issue for trial." Matsushita Elec. Indus. Co., Ltd. v. Zenith
Radio Corp., 475 U.S. 574, 587 (1986) (internal quotation marks omitted).
Discussion
1
Unfair Trade Practices Act
Litton Loan seeks summary judgment on Trachsel's Unfair Trade Practices Act ("UTPA")
claim on the ground that UTP A does not apply to the alleged conduct, and that ifUTP A applies, the
loan modification was not enforceable under the statute of frauds and for lack of consideration.
A.
Applicability of UTPA
Litton Loan argues that the UTPA claim must be dismissed because loans do not qualifY as
goods or services, the sale of which are protected by this statute. Trachsel responds that although
the provision of loans themselves is not subject to UTPA, the provision of loan services is. The
court must thus determine whether the misrepresentations allegedly made in the course of Trachsel 's
loan modification application process are properly construed as of the loan itself, or in the service
of the loan.
The Oregon COUli of Appeals addressed this question in some depth in Cullen v. Investment
Strategies, Inc., 139 Or. App. 119, 911 P.2d 936 (1996). There, the defendant was a mOligage
broker who, in the course of securing a personal residential loan for the plaintiffs, failed to disclose
that the loan carried a "higher than market interest rate" in order for the defendant to recover a larger
fee from the actual lender. The complaint characterized the misrepresentation as a "non-disclosure
regarding the nature of the loan transaction[.]" Id. at 122. The COUli of Appeals turned to three of
its prior decisions for guidance as to whether this misrepresentation was actionable under Oregon's
version of UTPA.
OPINION AND ORDER
6
{KPR}
First, the COUlt considered Haeger v. Johnson, 25 Or. App. 131, 548, P.2d 532 (1976),
wherein it held that lending money did not amount to a sale of goods or services and so was not
subject to UTPA. The Cullen court then turned its attention to Lall1l11 v. Amfac Mortgage Cmp., 44
Or. App. 203, 605 P.2d 730 (1980), which extended Haeger's reasoning to ORS 646.608(1)(s),
which refers to "false or misleading representations of fact concerning the offering price of, or the
person's cost foneal estate, goods 01' services." OR. REv. STAT. 646.608(1 )(s) (2009). Finally, the.
court revisited its decision in Roach v. Mead, 76 Or. App. 83,709 P.2d 246 (1985). There, the
UTPA claim was asserted by the lender, who alleged that the defendant had "advised him to accept
legally unenforceable promissoty notes in consideration for the loan." Cullen, 139 Or. at 125. The
COUlt of Appeals ruled that "[a] person who simply loans money, with no other factors involved,
cannot be within the protections of the UTPA." Roach, 76 Or. App. at 88.
The Cullen court concluded, in light of these decisions, that the professional services of a
non-lender in cotmection with a loan fall within UTPA: "Consequently, a non-lender's material
nondisclosures or misrepresentations regarding the character, quality, or cost of such services are
actionable under the UTP A. Thus, for example, a residential loan broker who misrepresents the
costs of its brokerage services is subject to UTPA liability." 139 Or. App. at 127. The court went
on to conclude that misrepresentations as to the terms of the loan itself are not actionable under
UTPA. /d. at 128. By this reasoning, the court concluded that misrepresentations by the mOltgage
broker regarding the interest rate and total cost of the loan were not actionable under UTP A. It
concluded, however, that the mortgage broker's failure to disclose the premium yield, the option to
finance at a lower rate, and the fees the broker would receive at the higher rate were actionable under
UTP A as "material nondisclosure[ s] ofinfonnation peltaining to the provision of brokerage services,
OPINION AND ORDER
7
{KPR}
as distinct from pmiicular loan terms." Id. at 129. This decision was recognized in this district in
Torrance v. Aames Funding, Corp., 242 F. Supp. 2d 862, 865 (D. Or. 2002): "Oregon law allows
claims under [] UTPA for loan services." (citing Cullen).
In a recent case involving multidistrict litigation, the cOUli rejected an Oregon UTPA claim
against Litton Loan, among other defendants, arising from the alleged misrepresentation that the
plaintiff qualified for a loan modification. The court wrote, quoting Cullen: "However, 'A loan is
not a "good" or "service" for UTP A purposes,' and 'material nondisclosures or misrepresentations
of loan attributes are not actionable under the UTPA.'" In re Mortgage Electronic Registration
Systems (MERS) Litigation, MDL Docket No. 09-2119-JAT, 2011 WL 4550189, at *10 (D. Ariz.
Oct. 3,2011). The court then noted that the plaintiffs had "attempt[ed], but fail[ed], to draw a
distinction that would save them from this exclusionary rule[,]" and thus summarily dismissed the
claim. However, this litigation concerned solely claims pertaining to the formation and operation
of MERS and not claims pertaining to loan collection or the requirements for obtaining a
modification. Accordingly, this decision does not undermine the ruling of Oregon courts that UTP A,
as set f01ih under Oregon law, may give rise to a claim for misrepresentations made in servicing a
loan, though not a claim arising from the terms of the loan itself.
Here, the court must determine whether Trachsel's allegations implicate the provision ofloan
services or the terms of the loan itself. Trachsel alleges, in relevant pmi, that Litton Loan
represented that the foreclosure was indefinitely on hold pending review of the loan modification;
that a decision as to modification was itself on hold pending action by President Obama on
foreclosure assistance; that Trachsel did not need to notarize his modification application; and that
his modification application was complete.
Trachsel further alleges that he was unable to
OPINION AND ORDER
8
{KPR}
communicate with Litton Loan after learning that his modification application had been denied and
that active foreclosure of his house had resumed.
The misrepresentations cited by Trachsel do not implicate the terms ofthe loan, nor do they
question the terms of the modification of the loan. Trachsel does not argue that the modification
should have been approved, nor does he seek to enforce the modification. Rather, all of Trachsel's
allegations with respect to his UTPA claim arise from Litton Loan's conduct in conducting the
modification and foreclosure processes, in patiicular those misrepresentations that ultimately resulted
in foreclosure of Trachsel's property.
Additionally, Litton Loan is a loan servicer and not a lender. It holds itself out as a servicer,
its full name being "Litton Loan Servicing, LP." Notably, at the bottom of the July 28,2009, letter,
it states: "Litton Loan Servicing LP is a debt collector. This is an attempt to collect your debt and
any information obtained will be used for that purpose." (Ledet Aff. Ex. 7.) Litton Loan does not
represent itself as a lender, nor does it purpOli to act in a lending capacity.
For these reasons, Trachsel's allegations cannot be characterized as pertaining to the lending
of money, or the terms of a loan or its modification. Rather, the allegations are more accurately
characterized as allegations arising from a loan servicing relationship and are thus actionable under
UTPA.
B.
Enforceability
Litton Loan argues that even if Trachsel can state a claim under UTP A such claim must fail
because the alleged modifications were neither in writing nor supported by consideration, and are
thus unenforceable. Trachsel responds that this claim does not arise in contract, he does not seek
to enforce an oral contract, and therefore these contractual deficiencies are irrelevant.
OPINION AND ORDER
9
{KPR}
The court agrees that Trachsel's claim does not sound in contract. Trachsel does not seek
to enforce a contract or other oral agreement; indeed, Trachsel does not argue that his loan agreement
was ever modified. The gravamen of Trachsel's claim is that Litton's unfair conduct in handling the
process for securing a modification prevented him from obtaining the modification and, ultimately,
caused him to lose his house. As such, the enforceability of the loan modification is not at issue.
C.
Reasonableness
Litton Loan argues that because foreclosure was a remedy authorized by the mortgage
agreement, foreclosure on Trachsel's property was per se reasonable, and that Trachsel's reliance
on its misrepresentations was otherwise umeasonable because the July 28,2009, letter informed him
that foreclosure was again underway. Trachsel responds that his reliance was reasonable because
he had not received notice of the second scheduled foreclosure as required by statute, and Litton
Loan made repeated oral representations that he would be informed prior to the reinitiation of
foreclosure.
UTPA prohibits a person, in the course of their "business, vocation or occupation" from
"[e]ngag[ing] in any other unfair or deceptive conduct in trade or commerce." OR. REv. STAT.
646.608(1)(u). Here, Trachsel claims that he was assured by Litton Loan that he did not need to
notarize his loan modification application; he was told that foreclosure of his property was on hold
indefinitely and that he would be notified when it was again underway; he was not notified of the
second foreclosure sale date; and that Litton Loan failed to respond to his inquiries and proceeded
to foreclose without providing notice or the opportunity to cure.
The court does not find the July 28, 2009, letter dispositive of this claim. First, the letter
continues the patte1'11 Trachsel had experienced so far, that Litton's written representations were
OPINION AND ORDER
10
{KPR}
inconsistent with the oral representations Litton gave him - and which had proved more accurate.
For example, Litton notified Trachsel in writing that foreclosure on his home would occur on May
8,2009, but foreclosure did not occur on that date, just as he alleges Litton told him orally it would
not be foreclosed. Thus, the letter affects no change in the parties dealings upon which Litton can
rely for summary judgment.
Second, the letter contains no clear statement that foreclosure would occur or that it would
occur on a specific date. In fact, the letter is equivocal on both points. On summary judgment, the
letter provides no basis for a ruling as a matter of law on the question of the respective parties'
reasonableness or unreasonableness. Third, Trachsel did exactly that which the letter informed him
to do, contact Litton Loan. It warns: "If foreclosure action has begun it will continue until you make
arrangements with us. Please call us today." (Ledet Dec!. Ex. 7.) The letter encouraged Trachsel
to pursue other loss mitigation options and gave a phone number at which to reach Litton Loan.
Trachsel claims that he contacted Litton Loan repeatedly, but was unable to make contact with a
representative and his calls went unreturned. Less than two weeks later, his home was sold at a
foreclosure sale for which he did not receive notice, or as represented to him by Litton Loan.
In light of Litton Loan's prior representations to Trachsel, the conditional language used in
the letter, and Litton Loan's unresponsiveness immediately prior to foreclosure of Trachsel's
propelly, the court concludes that there is an issue of fact as to whether Trachsel reasonably relied
on Litton Loan's misrepresentations. Accordingly, on the record before it, the COUll concludes that
there are genuine issues of material fact as to whether Litton Loan engaged in unfair or deceptive
conduct in its dealings with Trachsel prior to the foreclosure of his residential property.
D.
Actual Notice
OPINION AND ORDER
11
{KPR}
In its reply brief, Litton Loan argues that Trachsel received notice of the postponed
foreclosure date by public proclamation, which is sufficient under Oregon law. ORS 86.755(2)
states:
The trustee or the attorney for the trustee, or an agent that the trustee or the attorney
conducting the sale designates, may postpone the sale for one or more periods
totaling not more than 180 days from the original sale date, giving notice of each
adjournment by public proclamation made at the time and place set for sale.
OR. REV. STAT. 86.755(2) (2009). Thus, Litton Loan argues, the foreclosure was properly noticed
and Trachsel unreasonably relied on representations to the contrary. Litton Loan also argues in its
reply brief that it was not the party responsible for providing notice and, thus, it cannot be held
responsible for harms arising from Trachsel's reliance on the absence of notice offoreclosure and
that, in order to premise a claim on improper statutOlY notice, Trachsel must join LSI Title Company
of Oregon, LLC ("LSI"), as a necessary patty.
The court is not persuaded by Litton Loan's arguments. Trachsel does not dispute that he
was properly notified of the original foreclosure sale. Furthermore, he does not argue that Litton
Loan was responsible for providing statutory notice of the second foreclosure sale. In fact,
Trachsel's allegations are based on Litton Loan's own alleged misrepresentations regarding the
pendency of the foreclosure sale and not on Litton Loan's failure to provide statutory notice. As
such, evidence and argument regarding statutory notice of foreclosure does not form the basis for
the underlying claims. For these reasons, the court rejects Litton Loan's argument that statutory
notice of foreclosure absolves it of potential liability and that LSI must be joined in this action.
OPINION AND ORDER
12
{KPR}
A claim of fraud must set forth the following elements:
'(1) a representation; (2) its falsity; (3) its materiality; (4) the speaker's knowledge
of its falsity or ignorance of its truth; (5) [the speaker's1intent that it should be acted
on by the person and in the matter reasonably contemplated; (6) the hearer's
ignorance of its falsity; (7) [the hearer's1reliance on its truth; (8) [the hearer's1right
to rely thereon; (9) and [the hearer's1consequent and proximate injUlY.'
Merten v. Portland General Electric Co., 234 Or. App. 407, 416, 228 P.3d 623 (201 0) (citing Wieber
v. FedEx Ground Package System. Inc., 231 Or. App. 469, 480, 220 P.3d 68 (2009)) (brackets in
original). The Oregon Supreme COUIt has, alternatively, expressed the "essential elements" of a
fraud claim as: "the defendant made a made a material misrepresentation that was false; the
defendant did so knowing that the representation was false; the defendant intended the plaintiff to
rely on the misrepresentation; the plaintiff justifiably relied on the misrepresentation; and the
plaintiff was damaged as a result ofthat reliance." Strawn v. Farmers Ins. Co. a/Oregon, No. SC
S057629, 2011 WL 1886283, at *8 (Or. May 19, 2011). To adequately allege such a claim in federal
court, the plaintiff must comply with the requirements of Federal Rule of Civil Procedure 9(b),
which provides that allegations offraud be stated "with particularity[.]" FED. R. CIV. P. 9(b). To
state with particularity, the plaintiff must "state the time, place, and specific content of the false
representations as well as the identities of the patties to the misrepresentation." Schrieber Distrib.
Co. v. Serv-Well Furniture Co., 806 F.2d 1393,1401 (9th Cir. 1986); see also Bell Atlantic Corp.
v. Twombly, 550 U.S. 544, 569 n.4 (2007) (noting that a heightened pleading standard is required
for "certain subjects understood to raise a high risk of abusive litigation," citing Rule 9(b)).
Litton Loan argues that Trachsel's fraud claim must fail as a matter oflaw because Trachsel
knew the foreclosure sale was going forward and reliance on the verbal statements was thus
OPINION AND ORDER
13
{KPR}
umeasonable. Litton Loan specifically argues that Trachsel's reliance on its verbal representations
was not reasonable because the July 28, 2009, letter informed him that foreclosure had been
reinitiated, he was thus on notice, and reliance to the contrary was umeasonable. Furthermore, Litton
Loan argues, the calls Trachsel made to Litton Loan demonstrate that he had knowledge of the
foreclosure. Trachsel responds that, having not received the type of notice Oregon law requires prior
to a foreclosure sale, it was reasonable for him to rely on Litton Loan's representations that the
foreclosure sale was on hold, pending fmther notice. Trachsel also argues that his failure to secure
alternative financing is evidence that he relied on Litton Loan's representations that foreclosure was
not imminent. In pmticular, Trachsel points to the testimony of Lowenberg that he would have lent
Trachsel the money needed to avoid foreclosure, if necessary.
As to whether Trachsel could have cured his default prior to foreclosure, the testimony of
Trachsel and Lowenberg create at least a genuine issue of material fact. Finally, Litton Loan's
arguments as to contract enforceability are again inapplicable to Trachsel's fraud claim, as it does
not sound in contract.
For these reasons, the court concludes that there are genuine issues of material fact as to
whether Trachsel reasonably relied on Litton Loan's fraudulent representations, which reliance
resulted in the foreclosure of his home. Litton Loan's motion for summary judgment on this claim
is denied.
Conclusion
For the reasons stated, the COUlt concludes that there are genuine issues of material fact on
Trachsel's UTPA and fraud claims, and Litton Loan's motion for summmy judgment (#65) is
DENIED.
OPINION AND ORDER
14
{KPR}
IT IS SO ORDERED
DATED this 8th day of November, 2011.
6.! (J!--.
/j
(~~
JO " V. ACOSTA
OPINION AND ORDER
15
{KPR}
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?