Knight v. Northpointe Bank
300 Mich. App. 109
| Mich. Ct. App. | 2013Background
- Knight sues the Bank more than a decade after alleged invalid transfers of a 200-acre parcel by her mother to her sister via power of attorney.
- The 200 acres were previously transferred in 2001, 2003, and 2005 through related conveyances, with easements and reconfigurations across a 240-acre total parcel.
- The Bank obtained a mortgage from Cutro in 2005, secured by the 200 acres, later foreclosed in 2010, and purchased at sheriff’s sale in 2010; redemption expired in 2011.
- Knight alleged that Cutro’s self-dealing transfers were invalid, prompting a quiet-title-type claim to be adjudicated in equity.
- The trial court dismissed Knight’s claim as untimely under laches, finding the delay prejudicial to the Bank, and Knight appealed.
- On appeal, the court affirmed, holding laches barred Knight’s equitable suit to quiet title due to delay and prejudice, despite not running afoul of limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether laches bars Knight's claim | Knight argues laches does not apply to timely, vested-right claims. | Bank argues delay prejudiced its defense and warrants laches as a bar. | Yes; laches barred Knight. |
| Whether delay prejudiced the Bank enough to support laches | Knight contends prejudice is insufficient to bar relief. | Bank argues extended delay harmed witnesses and evidence and increased exposure. | Prejudice supported laches; relief denied. |
| Whether the Bank’s knowledge of potential defects precludes laches | Knight claims Bank could rely on facial invalidity of transfers to defend without laches. | Bank contends laches can apply even when defendant knew of potential defects. | Bank could invoke laches despite knowledge of defects. |
Key Cases Cited
- Campau v Chene, 1 Mich 400 (1850) (necessity of diligence in equity and cautions against stale claims)
- Lothian v Detroit, 414 Mich 160 (1982) (prejudice from delay governs laches analysis)
- Duck v McQueen, 263 Mich 325 (1933) (equity leaves parties where it finds them when laches applies)
- German American Seminary v Kiefer, 43 Mich 105 (1880) (protects against delayed suits where witnesses are dead or unavailable)
- Ford v Loomis, 33 Mich 121 (1876) (laches proper where delayed pursuit increases value of property)
