A.M. Samara v. Thomas Keith Taylor, 38 F.4th 141

In the 1990s Samara and Roy Davis entered a joint-venture wheat deal; Yemen defaulted and Davis ultimately recovered settlement proceeds, of which Samara claims he was owed half.
After extensive litigation, a district court entered judgment for Samara and imposed a constructive trust; subsequent settlement allowed Davis to post a mortgage to the court in 2006 in lieu of cash to stay execution.
The mortgage recorded in 2006 (attached to the parties’ proposed order) did not include a 107-acre tract called Parcel A, which Samara knew was owned solely by Voncile Davis; the appraisal filed around the same time listed the larger farm including Parcel A.
The district court dissolved the constructive trust in 2006 after finding the mortgage, title opinion, and appraisal satisfied the conditions; this dissolution was later vacated by the court of appeals on due-process grounds.
The district court’s mortgage was assigned to the bankruptcy trustee and then to Samara in 2012; Samara foreclosed and bought the mortgaged property in December 2012.
In 2019 Samara sued Thomas Taylor (Davis’s son‑in‑law), alleging Parcel A had been fraudulently transferred and seeking reformation of the mortgage; the district court granted judgment on the pleadings for Taylor, holding the claim time‑barred and insufficiently pleaded.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Samara's reformation claim is time‑barred under Alabama law	Statute of limitations began to run in 2012 when the mortgage was assigned to Samara (trustee), not when the mortgage was filed in 2006	Cause of action accrued when the mortgage was executed/delivered in 2006; ten‑year statute for recovery of land applies	Claim is time‑barred under Ala. Code § 6‑2‑33(2); 2006 accrual; 2019 suit untimely
Whether Samara plausibly alleged fraud or mistake to reform the mortgage	Facts and circumstances (including appraisal/mortgage discrepancy) imply fraud or mistake making reformation appropriate	Mortgage, district orders, and Samara’s own filings show Parcel A belonged solely to Voncile Davis and was intentionally excluded; reformation requires clear, convincing, satisfactory evidence	Even on the merits, pleadings fail to state a plausible reformation claim under Ala. Code § 35‑4‑153; dismissal on pleadings affirmed

Swan v. Magnusson, 418 So.2d 844 (Ala. 1982) (ten‑year statute for recovery of land applies to judgment‑creditor actions to subject property to creditor’s rights)
Scofield v. Cheatham, 485 So.2d 722 (Ala. 1986) (cause of action accrues upon execution and delivery of deed for purposes of limitations)
Pinto Credit Union v. Brown, 535 So.2d 139 (Ala. 1988) (ten‑year statute for recovery of land applies to judgment creditors)
U.S. Bank Nat'l Ass'n v. Shepherd, 202 So.3d 302 (Ala. 2015) (reformation under § 35‑4‑153 requires clear, convincing, and satisfactory evidence)
Mullinax v. Mullinax, 495 So.2d 646 (Ala. 1986) (standards for reformation evidence)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions insufficient; plausibility required)
Perez v. Wells Fargo N.A., 774 F.3d 1329 (11th Cir. 2014) (standard of review for judgment on the pleadings)