Steven Steptoe and Patricia Carballo v. JPMorgan Chase Bank, N.A.

OPINION

Laura Carter Higley, Justice

JPMorgan Chase Bank, N.A. (JPMC) filed suit against Steven Steptoe-and Patricia Carballo, seeking non-judicial foreclosure on a home-equity loan. Steptoe and Carballo moved for summary judgment on the ground that JPMC’s claim was a compulsory counterclaim that should have been brought by JPMC in an earlier suit. JPMC responded that its claim fell within an exception to the compulsory counterclaim rule. It filed a cross motion for summary judgment, asserting that it was entitled to judgment permitting non-judicial foreclosure, as a matter of law.

The trial…