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Knight v. Northpointe Bank
300 Mich. App. 109
| Mich. Ct. App. | 2013
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Background

  • 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)
Read the full case

Case Details

Case Name: Knight v. Northpointe Bank
Court Name: Michigan Court of Appeals
Date Published: Jan 24, 2013
Citation: 300 Mich. App. 109
Docket Number: Docket No. 310206
Court Abbreviation: Mich. Ct. App.