| ICSC Legal Database - Cases | Monday, February 22, 1999 05:01 PM |
| Citation: |
| Allendale Furniture v. Carolina Commer. Bank, 284 S.C. 76, 325 S.E.2d 530 (1985). |
| Issue: |
| Where a note provides for acceleration of maturity upon default "without further notice" and a payment is not |
| made when due, may mortgagee exercise its election to accelerate all payments without notifying the |
| Facts: |
| Mortgagor Furniture Company executed a $75,000 note and real estate mortgage to Bank, payments being due |
| on the first day of each month in the amount of approximately $919. For the first few years, payments were |
| made on time and after that, payments were late in some cases by several days and in other cases, by several |
| months. Bank accepted the late payments, but notified the Furniture Company on 37 occasions of the need for |
| compliance. Payment due February 1, 1980, was not received until February 22. It was returned by the Bank |
| advising that the mortgagor would hear from the Bank's attorney. On March 31, the Bank received and returned |
| both the February and March payments. The note provided that, in case of default, the principal sum with all |
| accrued interest shall become "at once" due and payable at the option of the holder "without further notice". |
| Mortgagee brought suit seeking foreclosure. The Master and Circuit Judge held that the default in payment |
| entitled the Bank to accelerate the maturity of the note and foreclose without further notice to the mortgagor. In |
| a split decision, the Court of Appeals, in its majority Opinion, reversed and held that the company's late tender |
| on February 22, of the payment due February 1, occurred prior to any affirmat ive act by the Bank notifying the |
| mortgagee of its election to accelerate, and, therefore, that payment cured the default. Mortgagee appealed. |
| Holding: |
| Reversed, and judgment of the Circuit Court affirmed. When payment was not made on the February 1, 1980 |
| due date, mortgagee's exercise of its election to accelerate all payments did not have to be communicated to |
| mortgagor or manifested by some affirmativ e act constituting notice to mortgagor of acceleration; the |
| morgagee's rejection, on February 22, of the late payment was sufficient for exercise of its right to accelerate |
| Classification 1: |
| Mortgages |
| 00119 - Legal Update - Winter 1985 |
|