Coleman v. Wilmington Savings Fund Soc'y.dissent

Summary

Justice Hart dissented from the denial of review and would have granted the petition. She reasoned that the appellate court relied on an outdated distinction between intrinsic and extrinsic fraud because Rule 60(c)(4) was amended in 2000 to permit judgments to be set aside for either type of fraud. The dissent therefore would have reviewed whether the alleged falsity in the affidavit of debt justified setting aside the foreclosure decree.