The Bateses appealed from a bankruptcy court ruling granting summary judgment to Citimortgage.  The district court affirmed, as did the First Circuit.

Citimortgage sent the Bateses a 1099-A form after foreclosing the mortgage.  The form had incorrect information on it.  This was disturbing and distressing to the Bateses because the form implied that they were still liable for the mortgage even though they received a chapter 7 discharge, and when they called Citimortgage to inquire, Citimortgage told them the same thing.  They reopened their bankruptcy case and filed an Adversary Proceeding.  The bankruptcy court granted Citimortgage summary judgment, and the district court and First Circuit affirmed.  There was a related issue concerning a recorded telephone call from Citimortgage demanding that they pay for insurance on the foreclosed property, but that issue was not before the First Circuit since the Bateses prevailed onthat as a discharge violation, but were awarded no damages.