Deutsche Bank v. Houck, 892 S.E.2d 280

In 1998 Houck purchased a mobile home, executed a $60,400 promissory note with a 15‑year balloon due July 1, 2013, secured by a mortgage; the note was later assigned to Deutsche Bank.
Houck conveyed the property to Tammy Bailey; Houck later died and her estate is a party.
In 2013 Petitioners sued the Bank for conversion, violations of the Attorney Preference Statute, and SCUTPA; at filing they were not in default but defaulted before the Bank answered.
The Bank did not assert a foreclosure counterclaim in the 2013 action; the jury returned a verdict for the Bank.
In 2016 the Bank filed a separate foreclosure action; Petitioners moved for partial summary judgment, arguing the foreclosure was a compulsory counterclaim under Rule 13(a) and thus barred.
The Master ruled for Petitioners; the court of appeals reversed under the "logical relationship" test, and the Supreme Court affirmed that result but prospectively abolished the logical relationship test, directing courts to apply Rule 13(a)'s plain language for cases filed on or after this opinion's effective date.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Bank's 2016 foreclosure was a compulsory counterclaim to the 2013 suit	Foreclosure arose from the same transaction/occurrence and thus was compulsory under Rule 13(a), so it's barred	Foreclosure was not compulsory because Petitioners were not in default when they sued and the claim did not arise from the same transaction	Court affirmed COA: foreclosure was not a compulsory counterclaim in the 2013 litigation
Whether the court should retain the "logical relationship" test to decide compulsory counterclaims	Logical relationship test should govern and bar later claims that are logically related	The plain text of Rule 13(a) should govern; the logical relationship test is uncertain and has expanded beyond Rule 13(a)	Court prospectively abolished the logical relationship test and directed application of Rule 13(a)'s plain language for future cases

Ziegler v. Dorchester Cnty., 426 S.C. 615, 828 S.E.2d 218 (2019) (standard of review: whether a counterclaim is compulsory is a question of law reviewed de novo)
North Carolina Fed. Sav. & Loan Ass'n v. DAV Corp., 298 S.C. 514, 381 S.E.2d 903 (1989) (South Carolina case that adopted the "logical relationship" test)
Deutsche Bank Nat'l Tr. Co. v. Est. of Houck, 434 S.C. 500, 863 S.E.2d 829 (Ct. App. 2021) (court of appeals held foreclosure not compulsory under the logical relationship test)
Carolina First Bank v. BADD, L.L.C., 414 S.C. 289, 778 S.E.2d 106 (2015) (example of later decisions applying the logical relationship approach)
Wachovia Bank, Nat'l Ass'n v. Blackburn, 407 S.C. 321, 755 S.E.2d 437 (2014) (case cited regarding the test's application)
Mullinax v. Bates, 317 S.C. 394, 453 S.E.2d 894 (1995) (earlier South Carolina decision applying logical relationship analysis)
First-Citizens Bank & Tr. Co. of S.C. v. Hucks, 305 S.C. 296, 408 S.E.2d 222 (1991) (prior case addressing counterclaims)