Turner v. Wells Fargo Bank, N.A.

Summary

The Supreme Court of Montana affirmed summary judgment for Wells Fargo in an action seeking release of a deed of trust on property purchased by the plaintiffs. The court held that the plaintiffs lacked standing to enforce the borrowers’ credit line agreement because they were not intended third-party beneficiaries. It also held that the plaintiffs failed to establish claims for promissory estoppel or equitable estoppel.

Holdings

1. The purchasers were not intended third-party beneficiaries of the credit-line agreement and therefore lacked standing to enforce it or seek release of the deed of trust.
2. The purchasers failed to establish a prima facie claim for promissory estoppel because Wells Fargo made no promise to them and they were not the parties to whom the alleged promise was made.
3. The purchasers failed to establish equitable estoppel because they did not rely to their detriment on Wells Fargo's later statement and had a readily available means of discovering that the deed of trust remained of record.

Questions Presented

1. Whether the purchasers of the property were intended third-party beneficiaries entitled to enforce the credit-line agreement and require Wells Fargo to release the deed of trust.
2. Whether promissory estoppel required Wells Fargo to release the deed of trust.
3. Whether equitable estoppel required Wells Fargo to release the deed of trust.

Disposition

affirmed