Jonathan Robbin

Jonathan Robbin

March 07, 2022 | Law.com

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 does not preclude a borrower from seeking redress in state court for violation of statute and pursuing statutory damages on an individual basis, but the decision narrows a borrower's ability to pursue class damages in federal court for failure to timely record mortgage satisfactions.

By Jonathan Robbin

4 minute read