This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Plaintiffs entered into agreements and loan transactions with a bank and its subsidiary to develop a business park. The subsidiary failed to provide promised funding, leading to financial difficulties for the Plaintiffs. The Defendants, acting as the Plaintiffs' legal counsel, failed to file administrative claims required under FIRREA, resulting in the dismissal of the Plaintiffs' federal court claims against the bank and the RTC for lack of subject matter jurisdiction (paras 2-5).
Procedural History
- Glenborough N.M. Assocs. v. Resolution Trust Corp., 802 F. Supp. 387 (D.N.M. 1992): The federal court dismissed the Plaintiffs' claims against the bank and the RTC for lack of subject matter jurisdiction due to the failure to file administrative claims. Claims against the subsidiary were dismissed under the D'Oench doctrine and 12 U.S.C. § 1823(e) (para 5).
- District Court, February 7, 1994: The district court granted summary judgment in favor of the Defendants in the legal malpractice action, finding no proximate cause between the Defendants' negligence and the Plaintiffs' alleged damages (paras 6-7).
Parties' Submissions
- Plaintiffs-Appellants: Argued that the Defendants' failure to file administrative claims under FIRREA prejudiced their ability to pursue claims against the bank and the RTC. They contended that the claims could have succeeded if the administrative filings had been made (para 8).
- Defendants-Appellees: Asserted that the Plaintiffs could not have prevailed on the merits of their claims against the bank and the RTC due to the requirements of the D'Oench doctrine and 12 U.S.C. § 1823(e). They argued that their failure to file administrative claims did not proximately cause any harm to the Plaintiffs (paras 8-9).
Legal Issues
- Whether the Defendants' failure to file administrative claims under FIRREA constituted legal malpractice.
- Whether the Plaintiffs could have prevailed on the merits of their claims against the bank and the RTC if the administrative claims had been filed.
- Whether the trial court erred in granting summary judgment on the additional claims in the amended complaint (paras 8-15).
Disposition
- The Court of Appeals affirmed the trial court's grant of summary judgment in favor of the Defendants (para 16).
Reasons
Per A. Joseph Alarid J. (Pickard and Flores JJ. concurring):
The Court held that the Plaintiffs could not have prevailed on the merits of their claims against the bank and the RTC under the D'Oench doctrine and 12 U.S.C. § 1823(e). The Plaintiffs failed to produce documentation meeting the statutory requirements, and their claims were based on alleged side agreements not properly documented. The Court found that any negligence by the Defendants in failing to file administrative claims did not proximately harm the Plaintiffs, as their claims would have been dismissed regardless (paras 10-13).
Regarding the amended complaint, the Court noted that the Plaintiffs had asserted during the summary judgment hearing that the amended complaint raised no new claims. The Plaintiffs could not later argue that the trial court erred in granting summary judgment on the additional claims. The Court emphasized that litigants cannot invite error and then seek to benefit from it (paras 14-15).