Murray v. Midland Funding, LLC
163 A.3d 271
| Md. Ct. Spec. App. | 2017Background
- Murray sued Midland Funding (an alleged unlicensed debt buyer) seeking to void a district-court judgment Midland had obtained and to recover or obtain equitable relief on behalf of a proposed class.
- By the time of the Anne Arundel circuit-court proceeding, all monetary claims had been dismissed; only declaratory and injunctive (equitable) counts remained.
- The circuit court dismissed those remaining counts as barred by the three-year statute of limitations (CJ §5-101). Murray appealed.
- After the circuit court decision, this Court decided Jason v. National Loan Recoveries, which addressed timeliness rules for Finch-style suits brought to void judgments obtained by unlicensed debt buyers.
- The Court of Special Appeals held the circuit court mistakenly applied a limitations bar to Murray’s equitable claims and remanded for reconsideration under the principles articulated in Jason.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Murray’s remaining claims (declaratory and injunctive) are barred by the three-year statute of limitations | Murray contends equitable relief to declare the judgment void and injunctive relief are timely; monetary claims were already dismissed | Midland argued the entire suit was time-barred under CJ §5-101 | Court vacated dismissal and remanded: simple declaratory relief is not time-barred; ancillary remedies may be subject to limitations or laches |
| Whether equitable remedies (injunction) are barred by laches | Murray seeks injunction preventing collection on the void judgment | Midland argues delay prejudices it and laches should bar equitable relief | Injunctive relief is subject to laches; court remanded so trial court can decide prejudice and delay issues |
| Whether a declaratory judgment that a judgment is void is subject to limitations or laches | Murray argues a declaration that a judgment is void can be obtained at any time | Midland contends ancillary remedies tied to a declaratory action may be stale | A simple declaration that a judgment is void can be obtained at any time (no statute of limitations or laches). Ancillary/remedial relief sought with the declaration may be subject to limitations or laches depending on whether the relief is legal or equitable |
| How to treat ancillary relief requested with a declaratory judgment (legal vs equitable) | Murray: ancillary relief is part of declaratory action and should proceed | Midland: ancillary relief (e.g., money recovery) is at law and time-barred | If ancillary relief is legal in nature it is subject to statutory limitations; if equitable, subject to laches. Court remanded to apply these principles |
Key Cases Cited
- Finch v. LVNV Funding, 212 Md. App. 748 (Md. Ct. Spec. App. 2013) (judgments obtained by unlicensed debt buyers are void)
- Jason v. National Loan Recoveries, 227 Md. App. 516 (Md. Ct. Spec. App. 2016) (rules on timeliness for declaratory actions to void judgments)
- Cook v. Alexandria Nat. Bank, 263 Md. 147 (Md. 1971) (void judgments may be attacked at any time)
- LaSalle Bank, N.A. v. Reeves, 173 Md. App. 392 (Md. Ct. Spec. App. 2007) (declaratory judgment may be legal or equitable depending on relief requested)
- Bowen v. City of Annapolis, 402 Md. 587 (Md. 2007) (declaratory judgment defines rights and must be in writing)
- Master Fin., Inc. v. Crowder, 409 Md. 51 (Md. 2009) (declaratory action seeking ancillary money relief treated as legal claim subject to limitations)
- Lopez v. State, 433 Md. 652 (Md. 2013) (laches explained as equitable time-defense)
- Dep’t of Human Serv. v. Kamp, 180 Md. App. 166 (Md. Ct. Spec. App. 2008) (laches bars where inexcusable delay and prejudice shown)
- State Ctr., LLC v. Lexington Charles Ltd. P’ship, 438 Md. 451 (Md. 2014) (equitable claims often measured against analogous legal limitations)
- Clark v. O’Malley, 186 Md. App. 194 (Md. Ct. Spec. App. 2009) (illustrating mootness of injunctive relief when underlying condition ended)
- United States v. One Toshiba Color Television, 213 F.3d 147 (3d Cir. 2000) (laches not available to bar attack on void judgment)