English v. Bankers Trust Company of California, N.A.
Florida District Court of Appeal
895 So.2d 1120 (2005)
Relevant factsFree
Bankers Trust (plaintiff) obtained a foreclosure judgment and deficiency award against Shana English (codefendant) without realizing she had previously transferred title to Lesa Investments (codefendant); after discovering this, the bank filed a second foreclosure action naming both English and Lesa, and English argued res judicata barred her renewed joinder given the first action's judgment and sale, though the trial court again ruled for the bank and assessed a fresh deficiency judgment.
IssueFree
Whether the legal title holder is an indispensable party to a foreclosure action.