Foreclosure Defense Process Challenges

Wrongful Foreclosure—Elements You Must Prove

To set aside a foreclosure sale or recover damages in California, you must prove specific legal elements. Here's what courts require and how to build your case.

3 Elements
Required
Tender
Usually Required
Prejudice
Must Show Harm
Act Fast
Time Matters

The Three Required Elements

California courts require you to prove all three of these elements to set aside a foreclosure sale:

1Illegal, Fraudulent, or Willfully Oppressive Sale

You must show the sale was conducted improperly. This can include:

2Prejudice (Harm) to Borrower

You must show the irregularity actually harmed you. Ask: would the outcome have been different without the violation?

3Tender of Amount Owed (Usually)

Generally, you must offer to pay the full amount owed to challenge the sale. However, there are important exceptions to the tender rule.

Key Case: Lona v. Citibank

In Lona v. Citibank (2011), the court held that to set aside a trustee's sale, the borrower must prove: (1) the sale was conducted in an illegal, fraudulent, or willfully oppressive manner; (2) the borrower was prejudiced; and (3) the borrower tendered or was excused from tendering.

Common Legal Theories

Wrongful foreclosure claims are typically based on one or more of these theories:

HBOR Violations (CC § 2924.12)

Dual tracking, no SPOC, failure to evaluate modification. Provides for injunctive relief before sale, damages after.

Breach of Contract

Servicer promised modification but foreclosed anyway. Requires written or oral agreement and reliance.

Fraud/Misrepresentation

Servicer lied about modification status, told you not to pay, or used robo-signed documents.

Promissory Estoppel

You relied on servicer's promise (e.g., "don't pay while we review") to your detriment.

Negligence

Servicer owed duty of care and breached it, causing harm. Duty can arise from HBOR or loan documents.

UCL (B&P § 17200)

Unfair business practices. Broad claim that can incorporate other violations. Allows for injunctive relief and restitution.

Quiet Title

Challenge lender's right to foreclose—broken chain of title, no standing, unrecorded assignment.

Cancellation of Instruments

Void the trustee's deed if sale was improper. Related to quiet title but focuses on the deed itself.

The Prejudice Requirement

California courts have become stricter about requiring proof of prejudice. Under the Yvanova line of cases:

Examples of Prejudice

Examples Where Prejudice is Hard to Show

Damages Available

If you prove wrongful foreclosure, you may recover:

Before Sale (Injunctive)

After Sale

FAQ

It depends on the claim:

  • HBOR claims - 1 year from recording of trustee's deed
  • Fraud - 3 years from discovery
  • Breach of contract - 4 years (written) or 2 years (oral)
  • UCL - 4 years
  • Quiet title - No fixed limit, but laches applies

Act quickly—delays hurt your case even within limitations periods.

A bona fide purchaser (BFP) makes setting aside the sale much harder. California law protects good-faith buyers who paid value without knowledge of problems. Your options:

  • Pursue money damages against servicer/lender instead
  • Argue sale was void (not voidable), which defeats BFP protection
  • Show purchaser had constructive notice of defects

Yes. Being in default doesn't excuse lender misconduct. However:

  • You still need to show prejudice—the violation must have affected the outcome
  • Tender requirement may still apply
  • Courts are skeptical if you couldn't have cured anyway

Focus on violations that prevented you from getting help you qualified for (modification, reinstatement opportunity, etc.).

Strongly recommended. Wrongful foreclosure cases are legally complex and involve:

  • Technical procedural requirements
  • Discovery disputes
  • Expert witnesses on damages
  • Well-funded opposing counsel

Many attorneys take these cases on contingency if there's a strong claim with substantial damages.

$240/hour

Think Your Foreclosure Was Wrongful?

I evaluate wrongful foreclosure claims and pursue cases where the evidence supports relief. If you lost your home to servicer misconduct, I can help you understand your options.

owner@terms.law Case Evaluation