Thomas v. JLC Wyoming, LLCAnnotate this Case
The Supreme Court reversed in part the district court's judgment granting JLC Wyoming LLC a deficiency judgment against Stanley Thomas for the unpaid amount of a judgment against Fourth Quarter Properties 86 (FQP) and Thomas, holding that the district court did not credit Thomas with all payments made against an earlier judgment.
FQP and Thomas obtained a $30 million loan from MetLife Insurance (MLIC) with a ranch as collateral, but when they could no longer make the payments, MLIC obtained a judgment against them for the outstanding balance plus interest (the judgment). Before the foreclosure sale, FQP filed for bankruptcy protection. MLIC purchased the ranch at a foreclosure sale. MLIC then sold its rights to the ranch and the remaining balance on the judgment to JLC. JLC obtained a deficiency judgment against Thomas for the unpaid amount of the judgment. The Supreme Court held (1) Thomas, a non-party to FQP’s bankruptcy case, was not entitled to the reduced amount FQP negotiated with MLIC in the bankruptcy case for the outstanding judgment; and (2) the district failed properly to credit Thomas for prior payments he and FQP made against the judgment.