MARIA CAPELES
v.
BANK OF AMERICA, N.A.

Fla. 3d DCA | 2020-12-23
No. 18-2581
Florida District Court of Appeal, Third District (2020)

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Holding

Where a mortgage contains an optional acceleration clause and the note has a definitive maturation date, the statute of limitations in foreclosure actions is determined under the Bartram framework.


Headnotes

[1] The Bartram standard for determining the statute of limitations in foreclosure actions applies where the mortgage contains an optional acceleration clause and the promiss…

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Facts & Procedural History

Maria Capeles appealed a circuit court decision in a mortgage foreclosure action brought by Bank of America. The mortgage at issue contained an option…

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Opinion of the Court

PER CURIAM.

Affirmed. See Hayes v. Reverse Mortg. Sols., Inc., 260 So. 3d 391, 395 (Fla.

3d DCA 2018) (holding that Bartram v. U.S. Bank National Ass’n, 211 So. 3d 1009,

1019 (Fla. 2016), applied where mortgage at issue contained optional acceleration clause and note had definitive maturation date); Nationstar Mortg. LLC v. LHF

Hudson, LLC, 271 So. 3d 1073, 1077 (Fla. 3d DCA 2019) (“As Bartram . . . did not change the law in Florida regarding the application of the statute of limitations in foreclosure actions, . . . Nationstar’s complaint [sufficiently] allege[d] that Hudson

‘defaulted under the Note and Mortgage by failing to pay the payment due January

, 2008 and all subsequent payments.’”).


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