Phoenix Funding, LLC v. Aurora Loan Servs., LLC

Summary

The New Mexico Supreme Court held that the 2009 default foreclosure judgment was not void for lack of jurisdiction because standing is not a jurisdictional prerequisite in common‑law mortgage actions, and it barred Phoenix Funding’s fraud claim as procedurally improper. The Court reversed the Court of Appeals, reinstated the district court’s summary judgment, and remanded with instructions to dismiss the fraud claim.