Reeves v. US Bank National Ass’n

After securing two loans with deeds of trust on the same property, Appellants paid off the smaller loan. A title agent filed a deed of reconveyance containing a scrivener’s error that mistakenly released Appellants’ interest in their property from the larger lien. Although the error was later corrected, Appellants argued that U.S. Bank, the beneficiary to the larger loan, did not have a valid, perfected lien prior to commencement of Appellants’ Chapter 7 bankruptcy proceedings. The district court granted U.S. Bank’s motion for judgment on the pleadings. The Supreme Court affirmed, holding that the lien at issue survived Appellants’ bankruptcy proceedings because the lien was unaffected by the scrivener’s error contained within the deed of reconveyance. View "Reeves v. US Bank National Ass’n" on Justia Law