Coan v. Championship Property, LLC
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In 2010, Crystal Kaye Coan purchased a property in Lauderdale County, which was subject to a mortgage. Coan defaulted on the mortgage, leading to a foreclosure by Carrington Mortgage Services, LLC, the mortgage assignee. Carrington sold the property to Championship Property, LLC in an online auction in May 2018. Championship then filed an ejectment action against Coan, claiming it was the title owner and seeking possession of the property. Coan countered that the foreclosure sale was void, and therefore, Championship had not acquired the title. In January 2023, Championship requested the trial court to require Coan to deposit $2,000 per month with the court clerk pending a final ruling in the ejectment action. The trial court, over Coan's objection, ordered her to deposit $800 per month.
Coan failed to deposit the court-ordered payments for March, April, and May 2023, leading Championship to move the trial court to hold her in contempt. The trial court found Coan in contempt and, as a sanction, ruled in favor of Championship on its ejectment claim, awarding it possession of the property. Coan appealed this decision.
The Supreme Court of Alabama affirmed the trial court's decision to require Coan to deposit $800 per month with the court clerk, stating that the trial court had the authority to enter the escrow order. The court also affirmed the trial court's finding of contempt against Coan for failing to comply with the escrow order. However, the court reversed the trial court's sanction awarding Championship possession of the property, stating that the sanction was not appropriate given the current posture of the litigation. The case was remanded to the trial court for further proceedings consistent with the Supreme Court's opinion.
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