BAC Home Loan Servicing L.P. v. State Resources Corp., 2:12-cv-00010

District Court reviewed BAC’s appeal of Bankruptcy Court orders in an adversary proceeding concerning a priority lien on the Naples Property.
SRC sought a declaratory judgment that its mortgage was a first lien superior to BAC’s interest.
BAC was served but failed to answer; a default Final Declaratory Judgment was entered against BAC and Robert E. Lee.
BAC moved to vacate the default judgment; the Bankruptcy Court denied; BAC timely filed a motion for rehearing, which was denied.
BAC’s first Notice of Appeal was deemed untimely and struck, leading to a sequence of notices and motions that the district court addressed.
Court ultimately held that the initial untimeliness rulings were reversible in light of tolling effects and Stern v. Marshall considerations on finality and jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was BAC’s first appeal timely after tolling?	BAC argues timely tolling via Rule 60(b) motion.	SRC contends timing was proper and untimely notices were correct.	Yes; timeliness of the first appeal was tolled by BAC’s Rule 60(b) motion.
Did the rehearing motion toll the appeal period further?	Rehearing extended the time for appealing the underlying judgments.	Rehearing did not toll the appeal period.	Yes; the rehearing tolled the time for filing the notices of appeal.
Did the Bankruptcy Court have subject-matter jurisdiction to enter the Final Declaratory Judgment?	Court lacked jurisdiction because property was not estate property.	The estate retained property interests through plan confirmation.	The Bankruptcy Court had subject-matter jurisdiction to enter the Final Declaratory Judgment.
Did the default judgment exceed the scope of relief requested in the complaint?	SRC sought declaration of first lien priority; no damages.	Judgment properly included damages and equity subrogation.	Parts of the default judgment exceeded the complaint’s scope and were void.
Whether Stern v. Marshall limits such final judgments in adversary proceedings under the 2011 interpretation?	Stern restricts final judgments by non-Article III courts.	Stern does not bar such judgments in this context; adversary proceedings are standalone.	Stern does not bar the final declaratory judgment here; the court retained authority.

Bowles v. Russell, 551 U.S. 205 (U.S. 2007) (jurisdictional requirement for notices of appeal)
Gulf Coast Fans, Inc. v. Midwest Electronics Importers, Inc., 740 F.2d 1499 (11th Cir. 1984) (Rule 60(b) tolling does not extend appeal time unless permitted)
Williams v. Bolger, 633 F.2d 410 (5th Cir. 1980) (Rule 60(b) tolling with pending Rule 59(e) motion tolls appeal time)
Cano v. Baker, 435 F.3d 1337 (11th Cir. 2006) (Rule 59(e) tolls appeal time when timely filed)
Nishimatsu Constr. Co. v. Houston Nat'l Bank, 515 F.2d 1200 (5th Cir. 1975) (default judgments require a valid basis in pleadings)
Stern v. Marshall, 131 S. Ct. 2594 (2011) (limits bankruptcy court final judgments for state-law counterclaims)
Katchen v. Landy, 382 U.S. 323 (1966) (claims allowance process and related judgments)
Langenkamp v. Culp, 498 U.S. 42 (1990) (standard for finality in bankruptcy contexts)
Burke v. Smith, 252 F.3d 1260 (11th Cir. 2001) (due process concerns with void judgments)
In re Bullock, 670 F.3d 1160 (11th Cir. 2012) (appellate jurisdiction over bankruptcy court orders)
Saylors, 11th Cir. 1989 (11th Cir.) (chapter 13 context and adversary proceedings)
In re Boca Arena, Inc., 184 F.3d 1285 (11th Cir. 1999) (adversary proceedings are stand-alone)