Midland Innovations, Nv v. Weiland Int'l Inc., 15-16015

Midland Innovations obtained a judgment against Wen Wang for patent infringement and recorded an abstract of judgment.
The house at issue had legal title in both Wen Wang and Weiping Chen when the judgment was recorded.
Chen and Wang later conveyed legal title to a third party, Hongdi Ren, for $300,000.
Midland sought to enforce its judgment lien against the house; Chen filed a third-party claim asserting she was not the beneficial owner.
The district court found the house subject to the judgment lien under California’s presumption that the legal title owner is the beneficial owner and denied Chen’s claim; Chen appealed.
The Ninth Circuit reviewed de novo and affirmed, concluding Chen failed to rebut the title presumption by clear and convincing evidence and that the post-judgment transfer to Ren did not defeat the lien.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the house was subject to Midland’s judgment lien under California law	Chen argued she was not the beneficial owner and thus the property should not be subject to the lien	Midland argued the presumption that legal title equals beneficial ownership applied and remained unrebutted	Court held the lien applied; Chen failed to rebut the presumption by clear and convincing evidence
Standard and burden of proof for third-party claim	Chen argued her evidence showed she lacked beneficial ownership	Midland argued California law places burden on claimant to prove otherwise at the hearing	Court held claimant bears the burden and must prove by clear and convincing evidence; Chen did not meet it
Admissibility and weight of Chen’s evidence	Chen relied on her proffered evidence and the conveyance to Ren to show lack of beneficial ownership	Midland contested reliability of Chen’s evidence and pointed to the timing of the abstract of judgment	Court exercised discretion to deem Chen’s evidence unreliable and declined to credit it
Effect of post-judgment transfer to Ren on the lien	Chen argued the transfer to Ren for $300,000 removed the property from the lien	Midland argued a transfer after recording does not extinguish a preexisting lien	Court held the transfer did not defeat the lien; interests remain subject to the judgment lien

Brunozzi v. Cable Commc’ns, Inc., 851 F.3d 990 (9th Cir. 2017) (issues of state law reviewed de novo)
NewGen, LLC v. Safe Cig, LLC, 840 F.3d 606 (9th Cir. 2016) (district court may consider new evidence in its discretion)
In re Marriage of Broderick, 209 Cal. App. 3d 489 (Cal. Ct. App. 1989) (tracing funds or undisclosed intent to grantee does not alone overcome title presumption)
United States v. Williams, 846 F.3d 303 (9th Cir. 2017) (arguments not raised below generally will not be considered on appeal)