Needham v. Fannie Mae, 854 F. Supp. 2d 1145

Needham, who borrowed from Wells Fargo and two senior lenders, faced foreclosure after defaulting on the Wells Fargo line of credit.
Wells Fargo foreclosed its lien before Needham’s bankruptcy, later modified terms by agreement with Needham, and received payments under the modification.
Needham filed for Chapter 13 bankruptcy; Wells Fargo’s payoff to senior lenders was later rescinded or adjusted after Needham’s bankruptcy filing.
The superior lender foreclosed, Wells Fargo’s lien was foreclosed in the process, and excess sale proceeds were interpleaded and adjudicated in Utah state court.
Needham asserts twelve claims including contract, unjust enrichment, fraud, quiet title, and Fair Housing Act violations; Wells Fargo seeks judgment on the pleadings.
The court applies Rule 12(c) standard, treats exhibits relied on by Wells Fargo as central to claims, and grants Wells Fargo’s motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether contract-based claims are viable	Needham contends Wells Fargo breached the note, deed of trust, and loan modification.	Wells Fargo argues no viable breach exists because modification extinguished prior duties and mispayments did not cause Loss.	Contract claims fail; no plausible breach shown.
Whether negligence claims survive economic loss rule	Needham alleges Wells Fargo breached duties in foreclosing and handling accounts.	Claims are tortious but arise from contractual duties; economic loss rule bars damages absent physical injury.	Negligence barred by economic loss rule; no physical damage alleged.
Whether fraud claims are cognizable given statute of frauds	Needham asserts various fraud theories relating to loan modification and foreclosure.	Oral promises to modify real property are unenforceable under the statute of frauds.	Fraud claims barred by statute of frauds.
Whether wrongful foreclosure and related claims survive	Needham argues improper foreclosure practices and defective documentation invalidate the sale.	Utah nonjudicial foreclosure does not require production of the original note; no remedy for the alleged irregularities.	Wrongful foreclosure claim fails; foreclosure validity upheld.

GFF Corp. v. Associated Wholesale Grocers, Inc., 130 F.3d 1381 (10th Cir.1997) (standard for evaluating affirmative defenses and pleadings)
MediaNews Group, Inc. v. McCarthey, 432 F.Supp.2d 1213 (D.Utah 2006) (authority for evaluating pleadings in federal court)
Commonwealth Prop. Advocates, LLC v. Mortg. Elec. Registration Sys., 263 P.3d 397 (Utah Ct.App.2011) (Utah case on mortgage registration and related duties)