In Zieve, Brodnax & Steele, LLP v.
Dhindsa, the California Court of Appeal held a
California statute that establishes the priority of payment of
proceeds from a nonjudicial foreclosure sale does not necessarily
require that junior lienholders receive surplus sale proceeds.
In Zieve, Manjit Dhindsa (“Manjit”) and
Malkit Dhindsa (“Malkit”) purchased a single-family
home located on Nikki Ann Way in Turlock, California (the
“Property”) with a loan secured by a first deed of
trust (the “First Deed of Trust”) from World Savings
and Loan Association (“World Savings”). Two years
later, Malkit executed a grant deed conveying his then fifty
percent interest in the Property equally to Manjit and Ashraj Singh
Dhindsa (“Ashraj”) as joint tenants. Ashraj is the son
and nephew of Manjit and Malkit, respectively.
