Barber v. U.S. Bank

CourtDistrict Court, D. Nebraska
DecidedFebruary 4, 2025
Docket8:24-cv-00426
StatusUnknown

This text of Barber v. U.S. Bank (Barber v. U.S. Bank) is published on Counsel Stack Legal Research, covering District Court, D. Nebraska primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barber v. U.S. Bank, (D. Neb. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEBRASKA

RAYSEAN D. BARBER,

Plaintiff, 8:24CV426

vs. MEMORANDUM AND ORDER U.S. BANK, CREDIT ONE BANK, and ELAN REGARDING DEFENDANTS’ MOTIONS FINANCIAL SERVICES, TO COMPEL ARBITRATION

Defendants.

In this case, pro se plaintiff RaySean Barber asserts claims against defendants identified as U.S. Bank, Credit One Bank, and Elan Financial Services arising from their handling of payments Barber made from his U.S. Bank account to Credit One Bank and Elan Financial Services that were reversed causing him to incur various fees. Filing 1. This case is now before the Court on the following motions: (1) the December 19, 2024, Motion to Compel Arbitration by Credit One Bank, N.A., (Credit One),1 Filing 13; and (2) the January 2, 2025, Motion to Compel Arbitration by defendants U.S. Bank National Association (U.S. Bank) and U.S. Bank d/b/a Elan Financial Services (Elan), (collectively, U.S. Bank Defendants),2 Filing 19. For the reasons stated below, the Motions to Compel Arbitration are granted.

1 Credit One asserts that it was improperly named in Barber’s Complaint as “Credit One Bank,” but that it is properly identified as “Credit One Bank, N.A.” Filing 13 at 1. Nevertheless, Credit One then identifies itself in its Motion to Compel Arbitration as “Credit One,” Filing 13 at 1, and the Court will do the same. 2 Defendant U.S. Bank asserts that it was improperly named in Barber’s Complaint as “U.S. Bank,” but that it is properly identified as “U.S. Bank National Association,” but it then identifies itself simply as “U.S. Bank.” Filing 19 at 1 & n.1. U.S. Bank asserts further that “upon information and belief, plaintiff is attempting to sue U.S. Bank in its capacity of doing business as Elan Financial Services.” Filing 19 at 1 n.1. U.S. Bank then identifies U.S. Bank and Elan Financial Services collectively as “Defendant.” Filing 19 at 1. The Court will generally refer to “U.S. Bank” and “Elan” as though they are separate defendants, consistent with the allegations in Barber’s Complaint and because the two entities assert separate arbitration agreements are controlling as to each of them. However, when referring to the second Motion to Compel Arbitration or arguments made in support of it, the Court will identify U.S. Bank and Elan collectively as the “U.S. Bank Defendants.” I. INTRODUCTION A. Preliminary Matters The Court notes that none of the defendants have filed answers to Barber’s Complaint before filing their Motions to Compel Arbitration. This procedural posture raises questions that none of the parties addressed about what Federal Rule of Civil Procedure is applicable and hence what record the Court can consider when ruling on the Motions.

The Eighth Circuit Court of Appeals has addressed the question: Upon careful review of the relevant authority, we agree ... that [a defendant’s pre-answer] motion [to compel arbitration] is properly analyzed under either Rule 12(b)(6) or Rule 56. To be sure, the motion does not sit squarely on all fours with either rule. We are nonetheless satisfied that, unlike the cases interpreting Rules 12(b)(1) or (b)(3), the legal authority does not forbid parties from using Rules 12(b)(6) or 56 to enforce an arbitration agreement. To the contrary, our sister circuits regularly employ Rules 12(b)(6) and 56 when deciding whether to compel arbitration. See Guidotti v. Legal Helpers Debt Resolution, L.L.C., 716 F.3d 764, 771 (3d Cir. 2013); Cnty. of McHenry v. Ins. Co. of the West, 438 F.3d 813, 817, 821 (7th Cir. 2006); see also Tinder v. Pinkerton Sec., 305 F.3d 728, 735 (7th Cir. 2002) (citing cases from the Second, Third, and Fifth Circuits and stating that “courts that have addressed the question have analogized the ... evidentiary standard a party seeking to avoid compelled arbitration must meet ... to that required of a party opposing summary judgment”). We decline to press the matter by deciding between Rule 12(b)(6) and 56, because summary judgment standards apply either way. In litigating [defendant’s] motion both parties submitted matters outside the pleadings, which the district court considered when granting the motion. Thus, even if the motion is construed under Rule 12(b)(6), it must ultimately “be treated as one for summary judgment under Rule 56.” See Fed. R. Civ. P. 12(d) (“If, on a motion under Rule 12(b)(6) ..., matters outside the pleadings are presented to and not excluded by the court, the motion must be treated as one for summary judgment under Rule 56.”); see also Evans v. McDonnell Aircraft Corp., 395 F.2d 359, 361 (8th Cir. 1968) (“Since both parties filed affidavits and exhibits in support of their respective positions, which were not excluded by the District Court, the motion to dismiss should properly have been treated as one for summary judgment.”). City of Benkelman, Nebraska v. Baseline Eng’g Corp., 867 F.3d 875, 881–82 (8th Cir. 2017). In this case—as in City of Benkelman—Credit One, the U.S. Bank Defendants, and Barber each submitted evidence in support of or opposition to the Motions to Compel Arbitration. See id.; see also Filing 14 (Credit One’s Index); Filing 21 (U.S. Bank Defendants’ Index); Filing 17 at 7–19 (Barber’s Affidavit in support of Brief in Opposition to Defendant Credit One Bank’s Motion to Compel Arbitration). Consequently, the Court will treat the Motions to Compel Arbitration as motions for summary judgment under Rule 56. Id.3 The Court notes that what claims are asserted and whether they are covered by the

arbitration agreements depend on how the Court views Barber’s pro se Complaint, even if summary judgment treatment is otherwise appropriate. Consequently, the Court notes that “[a] pro se complaint must be liberally construed, Estelle v. Gamble, 429 U.S. 97, 106 (1976), and ‘pro se litigants are held to a lesser pleading standard than other parties[,]’ Fed. Express Corp. v. Holowecki, 552 U.S. 389, 402 (2008).” Stone v. Harry, 364 F.3d 912, 915 (8th Cir. 2004); see also Topchian v. JPMorgan Chase Bank, N.A., 760 F.3d 843, 849 (8th Cir. 2014) (explaining the liberal construction given pro se pleadings). Even so, “[t]he liberal construction afforded a pro se pleading is limited by reasonableness: defendants must be given fair notice of the claims so that they may make a meaningful response to the pleadings.” Nelson v. Farm Credit Servs., 19 F.3d

1437, 1994 WL 87164, at *1 (8th Cir. 1994) (table op.) (citing Miles v. ERTL Co., 722 F.2d 434, 434-35 (8th Cir. 1983) (per curiam)). Therefore, the Court will not construe Barber’s Complaint to contain claims that cannot reasonably be found in that pleading in deciding what claims are asserted and whether they are arbitrable.

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Estelle v. Gamble
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Ilah M. Tinder v. Pinkerton Security
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Peters v. Woodmen Accident and Life Company
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Barber v. U.S. Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barber-v-us-bank-ned-2025.