The Bank of New York Mellon v. Dianne D. Glenville A/k/a Diane D. Glenville A/k/a Diane…

Summary

The Court held that the sixty-day period for filing claims to foreclosure-sale surplus funds begins when the clerk issues the certificate of disbursements, not at the public auction or upon issuance of the certificate of title. Because Mellon filed its claim within sixty days of that certificate, its claim was timely, and the Court quashed the contrary appellate decision while disapproving the conflicting decision to the extent it used the certificate of title as the trigger.