Nancy Alanis v. US Bank National Association as Successor Trustee to Bank of America National Association, as Successor by Merger to One LaSalle Bank, N.A. as Trustee for the MLMI Trust Series 2006-HE6
Nancy Alanis sued U.S. Bank National Association, BAC Home Loans Servicing, L.P., and The Law Offices of Mann & Stevens for fraud and violations of debt collection statutes related to the foreclosure of her San Antonio property. Following a jury trial, Alanis was awarded damages against U.S. Bank for Texas Fair Debt Collection Practices Act (FDCPA) violations and against BAC for common-law fraud, including attorney's fees, while Mann & Stevens received a take-nothing judgment. On appeal, Alanis challenged the denial of declaratory judgments, the granting of JNOV for Mann & Stevens, and the reduction of her damages due to settlement credits and comparative liability. U.S. Bank and BAC cross-appealed the damages for out-of-pocket expenses and attorney's fees. The appellate court affirmed the trial court's JNOV for Mann & Stevens and the application of comparative responsibility and settlement credit, but reversed the award of out-of-pocket damages and attorney's fees to Alanis, resulting in a net recovery of $0 for Alanis from U.S. Bank and BAC.