Wendy Richter v. Federal National Mortgage, 553 F. App'x 655

Hardy executed a promissory note to Integrity Lending, secured by a mortgage on real property in Wright County, Minnesota, with the mortgage held via MERS.
In March 2011, MERS assigned the mortgage to Chase Home Finance LLC by an assignment recorded in the county records.
Upon Hardy’s default, Chase foreclosed non-judicially and purchased the property at the Sheriff’s sale.
Chase subsequently conveyed the property to FNMA by a Quit Claim Deed.
Hardy filed suit challenging the foreclosure, seeking quiet title and damages, which the district court dismissed under Rule 12(b)(6).
On appeal, the Eighth Circuit affirmed, applying de novo review and concluding the complaint failed to plead a plausible claim under Rule 8.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the quiet title claim is viable given an unrecorded pre-foreclosure assignment	Hardy contends an unrecorded pre-foreclosure assignment to FNMA supports quiet title.	Appellees argue the claim is based on conclusory, speculative allegations not supported by the pleadings.	Dismissed; claim insufficient under Rule 8.

Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility pleading standard)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must contain plausible claims)
Shady Grove Orthopedic Assocs., P.A. v. Allstate Ins. Co., 559 U.S. 393 (2010) (federal courts in diversity apply state substantive law)
Karnatcheva v. JPMorgan Chase Bank, N.A., 704 F.3d 545 (8th Cir. 2013) (complaint must plead plausible claims; allegations must support validity of adverse claims)
Hathorn v. Butler, 75 N.W.2d 743 (Minn. 1898) (mortgage assignments must be recorded before foreclosure)