mortgage contingency clause (Massachusetts) · Go Syfert
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mortgage contingency clause in Massachusetts

13 Massachusetts opinions name it 4 courts 1987–2024 2 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Tremouliaris v. Pinagreen
massappct · 1987 · cited in 5 Massachusetts opinions naming this issue, 1994–2007
2 sentences

2002The contract contained a mortgage contingency clause which provided that “(i]f the BUYERS having used due diligence fail in good faith to obtain a loan commitment within 30 days then this agreement shall become null and void ...” Id. at 723 .

2001However, “[t]he essential function of a mortgage contingency clause is to enable a purchaser to escape liability and to assure the return of his deposit in the event that he is unable to obtain file amount or type of financing prerequisite to his realty purchase.” Id. at 726 .

45
Stabile v. McCarthygreen
mass · 1957 · cited in 4 Massachusetts opinions naming this issue, 1989–1996
2 sentences

1996A mortgage contingency clause permits a buyer to avoid his contractual obligation to purchase and to escape liability therefor upon the “happening of a condition precedent,” Stabile v. McCarthy, 336 Mass. 399, 402-403 (1957); namely, the buyer’s failure, after sufficient, appropriate effort, to obtain financing “in a stated amount and on stated terms” specified in the contingency clause.

1994See Sechrest v. Safiol, 383 Mass. 568, 571 (1981); Stabile v. McCarthy, 336 Mass. 399, 402-403 (1957).

24
Lynch v. Andrewgreen
massappct · 1985 · cited in 3 Massachusetts opinions naming this issue, 1989–2004
2 sentences

2004Lynch v. Andrew, 20 Mass. App. Ct. 623, 626 (1985).

1996Whether the Kulakowskis acted “diligently” to obtain the requisite financing contemplated by paragraph 27 was a “factual question, the determination of which is entitled to the customary appellate deference.” Lynch v. Andrew, 20 Mass. App. Ct. 623, 625 (1985).

23
Sechrest v. Safiolgreen
mass · 1981 · cited in 2 Massachusetts opinions naming this issue, 1989–1994
2 sentences

1994See Sechrest v. Safiol, 383 Mass. 568, 571 (1981); Stabile v. McCarthy, 336 Mass. 399, 402-403 (1957).

1989See, e.g., Sechrest v. Safiol, 383 Mass. 568 (1981); Stabile v. McCarthy, 336 Mass. 399 (1957); Lynch v. Andrew, 20 Mass. App. Ct. 623 (1985).

22
Churgin v. Hobbiegreen
massappct · 1995 · cited in 1 Massachusetts opinions naming this issue, 2007–2007
1 sentence

2007See Tremouliaris v. Pina, 23 Mass. App. Ct. 722, 726 (1987); Churgin v. Hobbie, 39 Mass. App. Ct. 302, 305 (1995).

11
Berry v. Nardozzigreen
mass · 1972 · cited in 1 Massachusetts opinions naming this issue, 2004–2004
1 sentence

2004A mortgage contingency clause is not intended to afford a haven to a buyer not acting in good faith seeking an escape from the agreement See Berry v. Nardozzi, 362 Mass. 145, 149 (1972).

11
Charles River Park, Inc. v. Boston Redevelopment Authoritygreen
massappct · 1990 · cited in 1 Massachusetts opinions naming this issue, 2002–2002
2 sentences

2002The Judsons counter in their cross motion for summary judgment that the mortgage contingency clause contained no date by which they were required to give notice of termination, only their deadline for obtaining financing. 2 They further assert that they gave notice within a reasonable time in December 1998 and, therefore, properly invoked the mortgage contingency clause. 3 See Charles River Park, Inc. v. Boston Redevelopment Authority, 28 Mass.App.Ct. 795, 814 (1990).

2002The Judsons counter in their cross motion for summary judgment that the mortgage contingency clause contained no date by which they were required to give notice of termination, only their deadline for obtaining financing. 2 They further assert that they gave notice within a reasonable time in December 1998 and, therefore, properly invoked the mortgage contingency clause. 3 See Charles River Park, Inc. v. Boston Redevelopment Authority, 28 Mass.App.Ct. 795, 814 (1990).

11
Miracle Revival Center Move of God Church v. Kindredgreen
texapp · 1981 · cited in 1 Massachusetts opinions naming this issue, 1987–1987
2 sentences

1987See Miracle Revival Center Move of God Church v. Kindred, 615 S.W.2d 257 (Tex. Ct. App. 1981).

1987See Miracle Revivial Center Move of God Church v. Kindred, 615 S.W.2d 257 (Tex. Ct. App. 1981).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
Bossi v. Whalen green
massappct · 1985
2 sentences

2001By imposing a deadline, a mortgage contingency clause ‘provide[s] him with a date by which he could know whether the buyers would have financing and would be bound to go through with the purchase.’” Id. at 967 .

1987By imposing a deadline, a mortgage contingency clause “provide[s] him with a date by which he could know whether the buyers would have financing and would be bound to go through with the purchase.” Bossi v. Whalen, 19 Mass. App. Ct. at 967 .

21987–2001
National Starch & Chemical Co. v. Greenberg green
massappct · 2004
1 sentence

2024Id.

12024–2024
Alfeo v. Dinsmore neutral
massappct · 2007
1 sentence

2021The Alfeo court observed that such a clause "incidentally benefits the seller by setting a certain date by which the deal may fail or after which the seller knows the buyer is bound to perform." Id. at 253 .

12021–2021
Commonwealth v. DeCologero green
massappct · 1985
1 sentence

2000Id.

12000–2000
DeWolfe New England v. Tich neutral
massdistctapp · 1989
1 sentence

1999The trial judge then concluded, however, that even though the plaintiffs gave notice before the deadline expired, “it was too late” because “[a] mortgage commitment under the terms of the parties’ contract had been issued by the lender and the plaintiffs’ choices were to either close on the property or forfeit their deposit.” This conclusion cannot be sustained “upon a reasonable view of the evidence adduced at trial.” See DeWolfe New England v. Tich, 1989 Mass. App. Div. 182, 184 .

11999–1999

Where else courts name it

NY 68 (1981–2026) CT 18 (1972–2022) MA 13 (1987–2024) IL 6 (1965–2019) NJ 6 (1991–2017) PA 4 (1983–2008)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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