Foreclosure Defense Post-Foreclosure

Set Aside the Trustee Sale—Get Your Home Back

If the foreclosure was wrongful, you may be able to void the trustee's deed and recover your property. Here's what California law requires to set aside a sale.

3 Elements
Must Prove
Void vs Voidable
Key Distinction
BFP Defense
Major Obstacle
Act Fast
Time Matters

Three Elements to Set Aside a Sale

Under California law (see Lona v. Citibank), you must prove all three:

1Illegal, Fraudulent, or Willfully Oppressive Sale

The sale must have been conducted improperly. Examples:

2Prejudice (Harm)

The violation must have actually harmed you:

3Tender (Usually)

Generally, you must offer to pay the full amount owed. But there are important exceptions:

Void vs. Voidable Sales

This distinction is critical:

Void Sale

Voidable Sale

The BFP Problem

If a bona fide purchaser (BFP) bought your home at or after the sale, setting aside becomes much harder. They paid value in good faith without knowledge of defects. Your remedy may be limited to money damages against the servicer/lender.

Claims to Plead

A set-aside lawsuit typically includes multiple causes of action:

  1. Cancellation of Instruments - Void the trustee's deed (CC § 3412)
  2. Quiet Title - Establish your ownership interest (CCP § 761.020)
  3. Wrongful Foreclosure - The underlying claim for damages
  4. HBOR Violations - CC § 2924.12 claims
  5. Fraud/Negligent Misrepresentation - If applicable
  6. UCL (B&P § 17200) - Unfair business practices
  7. Declaratory Relief - Court declaration of rights

Lis Pendens

File a lis pendens (notice of pending action) to put future buyers on notice. This can prevent the property from being sold to a BFP while your case is pending.

Statutes of Limitations

Time limits vary by claim:

Don't Wait

Every day you delay hurts your case. The property may be sold to a BFP. Evidence may be lost. Your memory fades. Statutes of limitations run. File as soon as possible after the sale.

FAQ

If the lender bought at the sale (credit bid), you're in better shape than if a third party bought:

  • Lender is not a BFP—they can't claim ignorance of their own violations
  • Property is still REO (real estate owned), making set-aside more feasible
  • No innocent third party's interests at stake

Act quickly before they sell to someone else.

Yes. If set-aside is impossible (BFP purchased, you can't tender), you can still pursue:

  • HBOR statutory damages - Greater of treble actual damages or $50,000
  • Actual damages - Lost equity, moving costs, emotional distress
  • Attorney's fees - Under HBOR and other statutes
  • Punitive damages - For egregious conduct

If you successfully set aside the sale:

  • Trustee's deed is void—title reverts to you
  • Current occupant (if any) must vacate or negotiate with you
  • If BFP, they may have claims against the seller for breach of warranty
  • Practical complications—eviction, damage claims, etc.—can take additional time

Expect 1-3 years for full litigation, though results vary:

  • Some cases settle early once lender sees strong claims
  • Summary judgment motions can resolve issues faster
  • Trial and appeal can extend timeline significantly
  • Lis pendens keeps property from being sold during litigation
$240/hour

Think Your Foreclosure Can Be Set Aside?

I evaluate set-aside cases and pursue claims where the evidence supports relief. If servicer misconduct caused you to lose your home, I can help you understand your options.

owner@terms.law Case Evaluation