In October 2014, we blogged about cases from Nevada and D.C. giving priority of so-called HOA “superliens” over first position mortgages. In a 2-1 decision, the United States Court of Appeals for the Ninth Circuit overruled the 2014 decision from the Nevada Supreme Court about which that, as a matter of lien priority, the foreclosure of a superlien for HOA assessments can extinguish a first mortgage.