Second Circuit Reverses Course and Denies Article III Standing for Statutory Damage Claims Arising Out of Untimely Recording of Mortgage Discharges

Maddox v. Bank of N.Y. Mellon Trust certainly affords safeguards to lenders and mortgagees in that Maddox now narrows a borrower's ability to pursue class damages in federal court for lenders and services for failure to timely record mortgage satisfactions.

4 minute read March 01, 2022 at 01:26 AM
By
Jonathan Robbin
Second Circuit Reverses Course and Denies Article III Standing for Statutory Damage Claims Arising Out of Untimely Recording of Mortgage Discharges

If at first you don't succeed, try again. In Maddox v. Bank of N.Y. Mellon Trust Co., N.A., the United States Court of Appeals for the Second Circuit got it right by vacating its prior order in light of the Supreme Court's TransUnion LLC v.

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