Burnette Avakian v. Citibank, N.A.

EDITH BROWN CLEMENT, Circuit Judge:

Defendant-Appellant Citibank, N.A. (“Citibank”) appeals the district court’s declaratory judgment in favor of Burnette Avakian (“Burnette”). The district court found that the deeds of trust signed by Burnette and her husband, Norair Avakian (“Norair”), were void because the Avakians signed separate but identical deeds of trust rather than a single instrument. The district court correctly recognized that, under Mississippi law, a deed of trust on a husband and wife’s homestead is void if it is not signed by both spouses. But we find that the Mississippi…