3rd Circuit Finds Claims Against Bank Are Barred By New Jersey Doctrine

Mealey's (March 27, 2018, 1:57 PM EDT) -- PHILADELPHIA — Because a borrower could have asserted her fraud and breach of contract claims related to a loan modification in an underlying state foreclosure case, the Third Circuit U.S. Court of Appeals on March 23 affirmed dismissal of the case as barred by the New Jersey entire controversy doctrine (Kimberly Shibles v. Bank of America, N.A., No. 17-2386, 3rd Cir., 2018 U.S. App. LEXIS 7341)....