Bass v. Aidvantage Fed. Student Aid Loan Servicing

CourtDistrict Court, W.D. Kentucky
DecidedSeptember 25, 2024
Docket3:24-cv-00279
StatusUnknown

This text of Bass v. Aidvantage Fed. Student Aid Loan Servicing (Bass v. Aidvantage Fed. Student Aid Loan Servicing) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bass v. Aidvantage Fed. Student Aid Loan Servicing, (W.D. Ky. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION

YAEL BASS Plaintiff

v. Civil Action No. 3:24-cv-279

AIDVANTAGE FED. STUDENT LOAN Defendants SERVICING AND EQUIFAX INFORMATION SERVICES, LLC

* * * * *

MEMORANDUM OPINION & ORDER

Defendant Maximus Education LLC d/b/a Aidvantage (“Aidvantage”)1 moves to dismiss under Fed. R. Civ. P. 12(b)(6) for failure to state a claim upon which relief can be granted. [DE 13].2 Plaintiff Yael Bass (“Bass”) has not responded, and the time to do so has expired. This matter is ripe. For the reasons below, Aidvantage’s Motion to Dismiss is GRANTED. [DE 13]. I. BACKGROUND This action arises from Bass’s claims against Aidvantage for violating the Federal Credit Reporting Act (“FCRA”), 15 U.S.C. § 1681 et seq.3 Bass is considered a “consumer,” Aidvantage

1 Incorrectly named as “Aidvantage federal student aid loan servicing” in the Complaint. [DE 1-1]. 2 The Joint Local Rules for the Eastern and Western Districts of Kentucky contemplate a single, unified motion and memorandum. See Local Rule 7.1. Going forward, counsel is advised to file a unified motion. 3 The factual allegations in the Complaint [DE 1] are considered true for purposes of this motion. See Tackett v. M & G Polymers, USA, LLC, 561 F.3d 478, 488 (6th Cir. 2009) (citing Gunasekera v. Irwin, 551 F.3d 461, 466 (6th Cir. 2009)). is considered a “furnisher of information,” and Equifax is considered a “consumer reporting agencies” (“CRA”) as defined by 15 U.S.C. § 1681s-2.4 In July 2023, Bass accessed her Equifax credit reports and discovered that Aidvantage was furnishing an alleged default history on her Aidvantage student loan account to Equifax. [DE 1-1 at 9]. On discovery, Bass disputed the account to Equifax in writing. [Id.]. In August 2023, Bass

accessed her Equifax credit report again, and found that the alleged inaccuracy was still reported. [Id.]. Although it is unclear, Bass appears to allege that she has a Federal Family Education Loan, serviced by Aidvantage, and Aidvantage furnished negative information about that loan on her Equifax credit report. [DE 1-1 at 10; DE 13-1 at 38]. Bass argues that Aidvantage negligently and willfully violated the FCRA because Aidvantage (1) failed to investigate Bass’s direct dispute; (2) failed to evaluate or consider any of Bass’s information, claims, or evidence; and (3) failed to make any and/or sufficient attempts to amend or delete its reporting of the disputed items within a reasonable time following receipt of Bass’s disputes. [DE 1-1 at 10-11]. Bass asserts that these

failures amount to Aidvantage breaching its duties to (1) ensure maximum possible accuracy of consumer reports under 15 U.S.C.§ 1681e(b) and, (2) investigate disputed items under 15 U.S.C. §1681i. [Id.].

4 The FCRA defines “consumer” to mean individual. 15 U.S.C. § 1681a(c). The FCRA defines a consumer reporting agency as “any person which, for monetary fees, dues, or on a cooperative nonprofit basis, regularly engages in whole or in part in the practice of assembling or evaluating consumer credit information or other information on consumers for the purpose of furnishing consumer reports to third parties, and which uses any means or facility of interstate commerce for the purpose of preparing or furnishing consumer reports.” § 1681a(f). The FCRA does not define “furnisher,” however, other courts have defined a furnisher as “any entity which transmits information concerning a particular debt owed by a particular customer to consumer reporting agencies.” Carney v. Experian Info. Sols., Inc., 57 F. Supp. 2d 496, 501 (W.D. Tenn. 1999). II. STANDARD A motion to dismiss under Fed. R. Civ. P. 12(b)(6) tests the legal sufficiency of the complaint. RMI Titanium Co. v. Westinghouse Elec. Corp., 78 F.3d 1125, 1134 (6th Cir. 1996). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678

(2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). A claim is plausible on its face “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). This standard does not “impose a probability requirement at the pleading stage; it simply calls for enough fact to raise a reasonable expectation that discovery will reveal evidence of illegal [conduct].” Twombly, 550 U.S. at 556. Dismissal under Rule 12(b)(6) is warranted “only if it appears beyond doubt that the plaintiff can prove no set of facts in support of the claims that would entitle him or her to relief.” Zaluski v. United Am. Healthcare Corp., 527 F.3d 564, 570 (6th Cir. 2008).

Because a motion to dismiss challenges the sufficiency of the pleadings, “[i]t is not the function of the court [in ruling on such a motion] to weigh evidence.” Miller v. Currie, 50 F.3d 373, 377 (6th Cir. 1995). Rather, to determine whether the plaintiff set forth a “plausible” claim, the Court “must construe the complaint liberally in the plaintiff's favor and accept as true all factual allegations and permissible inferences therein.” Gazette v. City of Pontiac, 41 F.3d 1061, 1064 (6th Cir. 1994). However, the Court is “not bound to accept as true a legal conclusion couched as a factual allegation”; “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 555). In deciding a motion to dismiss, the Court “may consider the Complaint and any exhibits attached thereto, public records, items appearing in the record of the case and exhibits attached to defendant’s motion to dismiss so long as they are referred to in the Complaint and are central to the claims contained therein.” Bassett v. Nat’l Collegiate Athletic Ass’n, 528 F.3d 426, 430 (6th Cir. 2008) (citation omitted). The Sixth Circuit has held that “if a plaintiff fails to respond or to otherwise oppose a

defendant's motion, then the district court may deem the plaintiff to have waived opposition to the motion.” Scott v. State of Tenn,

Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Daisy B. Scott v. State of Tennessee
878 F.2d 382 (Sixth Circuit, 1989)
Gazette v. City Of Pontiac
41 F.3d 1061 (Sixth Circuit, 1994)
Miller v. Currie
50 F.3d 373 (Sixth Circuit, 1995)
Bassett v. National Collegiate Athletic Ass'n
528 F.3d 426 (Sixth Circuit, 2008)
Tackett v. M & G POLYMERS, USA, LLC
561 F.3d 478 (Sixth Circuit, 2009)
Gunasekera v. Irwin
551 F.3d 461 (Sixth Circuit, 2009)
Zaluski v. United American Healthcare Corp.
527 F.3d 564 (Sixth Circuit, 2008)
Stafford v. Cross Country Bank
262 F. Supp. 2d 776 (W.D. Kentucky, 2003)
Carney v. Experian Information Solutions, Inc.
57 F. Supp. 2d 496 (W.D. Tennessee, 1999)
Lewis v. Ohio Professional Electronic Network LLC
248 F. Supp. 2d 693 (S.D. Ohio, 2003)
Scott Merritt v. Experian
560 F. App'x 525 (Sixth Circuit, 2014)
Michael Scott v. First S. Nat'l Bank
936 F.3d 509 (Sixth Circuit, 2019)

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Bass v. Aidvantage Fed. Student Aid Loan Servicing, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bass-v-aidvantage-fed-student-aid-loan-servicing-kywd-2024.