CELINK v. Estate of Pyle

Celink v. The Estate of William R. Pyle No. 0940, September Term 2022 Opinion by Kehoe, J. Mortgages and Deeds of Trust — Destruction of Premises by Fire When the improvements on a secured property are destroyed by fire and the loan is due and payable, Maryland applies the “loss before foreclosure rule.” The rule provides: Where a mortgagee has a right to foreclose a mortgage because the mortgage obligation is fully due and payable and the mortgagee has a right to casualty insurance . . . the mortgagee may either: (1) recover from the insurance proceeds . . .; or (2) foreclose on the…