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Chemical Bank v. Weiss

Citations: 88 A.D.2d 686; 450 N.Y.S.2d 899; 1982 N.Y. App. Div. LEXIS 16931

Court: Appellate Division of the Supreme Court of the State of New York; May 6, 1982; New York; State Appellate Court

Narrative Opinion Summary

The case involves an appeal from a Supreme Court order denying Chemical Bank's motion for summary judgment concerning a $1,650,000 loan secured by a first mortgage on an apartment complex. M.L.M. Associates, Inc. had transferred the property to Colonie Associates while retaining the mortgage lien. A modification agreement reduced the principal owed, and personal guarantees were executed by Weiss, a partner and CEO, for tax and interest obligations. Following a default on these payments, Chemical Bank filed a lawsuit to foreclose on the mortgage and obtain a judgment against Weiss for failing to honor his guarantees. The defendants claimed an oral contract for a $250,000 loan from the bank to cover taxes, arguing this breach justified their defenses against foreclosure and guarantees. The lower court initially denied Chemical Bank's motions to dismiss these defenses and counterclaims. On appeal, however, the court reversed this decision, ruling the defenses and counterclaims legally ineffective and emphasizing that denials unsupported by evidence cannot defeat a summary judgment motion. Applying the law of the case doctrine, the appellate court granted summary judgment in favor of Chemical Bank and remanded for the appointment of a referee to calculate the amount owed.

Legal Issues Addressed

Enforcement of Mortgage and Guarantee Obligations

Application: The court affirmed the enforceability of the mortgage and guarantee obligations despite the defendants' claims of an oral contract, granting Chemical Bank's motion for summary judgment.

Reasoning: The court initially denied Chemical Bank's motion to dismiss these defenses and counterclaims. However, on appeal, the court reversed that part of the order, dismissing the affirmative defenses and counterclaims as legally ineffective.

Law of the Case Doctrine

Application: The appellate court applied the law of the case doctrine to reverse the lower court's denial of summary judgment, indicating that prior appellate decisions on the same issues are binding.

Reasoning: Citing the law of the case doctrine, the court ruled in favor of Chemical Bank, granting summary judgment.

Summary Judgment Standards

Application: The appellate court emphasized that denials unsupported by evidence are insufficient to defeat a motion for summary judgment.

Reasoning: On appeal, the court clarified that the issue of conditional denials was not crucial since mere denials without supporting evidence do not suffice to challenge a summary judgment motion.