Roe v. Deutsche Bank National Trust Company NA, 3:24-cv-05338

Jan Roe owned real property in Washington and executed a deed of trust securing a 2006 loan.
She filed for Chapter 7 bankruptcy in 2010, obtaining a discharge in 2011, and made no further payments on the loan.
In 2020, Roe brought a quiet title action in state court, arguing that her bankruptcy discharge started the statute of limitations (SOL) clock for foreclosure, which lapsed in 2017.
During the pending action, the Washington Supreme Court clarified in Copper Creek and Merritt that bankruptcy discharge does not trigger the SOL for enforcing a deed of trust.
Roe voluntarily dismissed her state case and refiled in federal court, advancing similar arguments and asserting a Supremacy Clause conflict.
Defendants moved to dismiss for failure to state a claim and sought sanctions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does bankruptcy discharge trigger the statute of limitations on a deed of trust?	Discharge in 2011 accelerated the loan and started the SOL, so foreclosure is now barred.	Discharge affects only personal liability; SOL runs as installments come due, unless the loan is accelerated, which did not occur.	No; SOL not triggered by discharge, and deed of trust remains enforceable until maturity or acceleration.
Should the federal court follow earlier federal interpretations or new state supreme court law?	Federal courts should follow Edmundson & its progeny, not Copper Creek and Merritt.	Washington Supreme Court is the final authority on state law; federal courts must follow Copper Creek and Merritt.	State supreme court's interpretation governs; federal courts apply it in diversity cases.
Is there a Supremacy Clause conflict between the Bankruptcy Code and Washington law on foreclosure?	Federal law preempts state law; discharge voids all claims against the property.	Bankruptcy law only extinguishes personal liability, not in rem (property) rights. No preemption.	No conflict; bankruptcy discharges only personal liability, not in rem rights.
Are sanctions against Plaintiff and counsel appropriate here?	No bad faith or violation; arguments were novel.	Refiling was meritless and in bad faith; violated procedural rules.	No sufficient evidence of bad faith; procedural requirements for sanctions not met.

Copper Creek (Marysville) Homeowners Ass'n v. Kurtz, 1 Wn.3d 711 (Wash. 2023) (bankruptcy discharge does not accelerate the maturity date or trigger the six-year statute of limitations on a deed of trust)
Merritt v. USAA Federal Savings Bank, 1 Wn.3d 692 (Wash. 2023) (discharge of personal liability in bankruptcy does not trigger the statute of limitations on the lien)
Johnson v. Home State Bank, 501 U.S. 78 (1991) (bankruptcy discharge eliminates only personal liability, not in rem claims against property)