Patterson v. CitiMortgage, Inc. 820 F.3d 1273 (11th Cir. 2016)

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Case Brief
Patterson v. CitiMortgage, Inc. 820 F.3d 1273 (11th Cir. 2016)
* FACTS
CitiMortgage (Plaintiff) made a unilateral mistake by sending Patterson (Defendant) a letter indicating a net payout amount of $113,968.45 instead of the $423,940 needed to clear the balance on Patterson’s house. Patterson received the letter and proceeded to pay the misquoted amount of $113,968.45. CitiMortgage rejected the amount and later received a letter from Patterson demanding that it accept the $113,968.45 payment. CitiMortgage then commenced foreclosure proceedings on the Breedlove property, which prompted Patterson to file a complaint in state court against CitiMortgage for breach of contract. CitiMortgage in turn removed the case to federal court.
* JUDGMENT
The federal court granted the motion.
* LEGAL PRIINCIPLE
* ISSUE
Whether the Federal Court was right in granting CitiMortgage the motion to reject the amount based on the mistake it made.
* HOLDING
Yes
* REASONING
* GENERAL ANALYSIS
In contract law, a mistake is a belief about a fact that is not in accord with the truth. Section 157 of the Restatement (Second) of Contracts covers the degree of a party’s negligence in making a mistake. According to this principle, a person’s fault in failing to know or discover facts before entering a contract will not bar relief unless the fault amounted to a failure to act in good faith. An important factor that affects the right to avoid a contract is whether the mistake was made by one of the parties, also called a unilateral mistake or by both parties, called a mutual mistake. In unilateral contract, the courts are likely to allow avoidance of a contract when both parties are mistaken than when only one party is mistaken. In order to avoid contracts of unilateral mistake, one has to prove the elements necessary for mutual mistake. Besides proving the elements of mistake, one has to show that either the non-mistaken party had reason to know of the mistake, or it would be unconscionable to enforce the contract.
* APPLIED ANALYSIS
The mistake ...