Branscumb v. Horizon Bancorp, Inc.

CourtDistrict Court, W.D. Michigan
DecidedMarch 19, 2024
Docket1:23-cv-00053
StatusUnknown

This text of Branscumb v. Horizon Bancorp, Inc. (Branscumb v. Horizon Bancorp, Inc.) is published on Counsel Stack Legal Research, covering District Court, W.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Branscumb v. Horizon Bancorp, Inc., (W.D. Mich. 2024).

Opinion

WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

TAMICA BRANSCUMB,

Plaintiff, Case No. 1:23-cv-53 v. Hon. Hala Y. Jarbou HORIZON BANCORP, INC.,

Defendant. ___________________________________/ OPINION Plaintiff Tamica Branscumb brings a claim of race discrimination under 42 U.S.C. § 1981 and Michigan’s Elliott-Larsen Civil Rights Act (“ELCRA”) against Defendant Horizon Bancorp, Inc. Before the Court is Horizon’s motion for summary judgment (ECF No. 53). For the reasons herein, the Court will grant the motion and dismiss the case. I. BACKGROUND The following is a summary of the evidence with the facts construed in a light most favorable to Branscumb and drawing all reasonable inferences in her favor. Branscumb is an African American woman. (Branscumb Aff., ECF No. 56-4, PageID.697.) She opened checking and savings accounts with Horizon in December 2020. (12/29/2020 Checking Account Agreement, ECF No. 54-1; 12/29/2020 Savings Account Agreement, ECF No. 54-2; Branscumb Dep. 13-17, ECF Nos. 54-19, 56-6.) Seven months later, Horizon shut down the checking account because it was overdrawn, meaning there was not enough money in the checking account to cover the checks she had written. (Branscumb Dep. 17-18.) On July 30, 2021, Branscumb went to a Horizon branch on Niles Road in St. Joseph, Michigan, to address the issue. There, a customer service representative named Kayla Betker 26; 7/30/2021 Checking Account Agreement, ECF No. 54-4; 8/22/2021 Account Statement, ECF No. 54-9.) Branscumb knew Betker by name because Betker often assisted Branscumb when Branscumb came into the bank. (Id.) After opening the new account, Branscumb repeatedly overdrew on it, resulting in negative account balances. (Account Statements, ECF No. 54-9, PageID.461, 465, 468; Branscumb Dep. 27-28.)

A. Branscumb Deposits Settlement Check to Checking Account (March 23, 2022) In March 2022, Branscumb received a check for $22,616.44 in connection with the settlement of a lawsuit. (Branscumb Dep. 30-31.) She had never before deposited an amount that large into her account. (Id. at 31.) As of March 22, her checking account balance was approximately $5.00 (See Account Statements, ECF No. 54-9, PageID.472.) On March 23, 2022, she went to the Niles Road branch to deposit her check. As before, Betker assisted her. (Branscumb Dep. 32.) Horizon had policies in place for assessing the legitimacy of a check presented for cash or deposit, in order to protect itself and its customers from fraud. (See Placing a Reg CC Hold, ECF No. 54-20; Negotiable Instrument Decision Making Guide, ECF No. 54-23.) One of those policies,

the guidelines for “Placing a Reg CC Hold,” instructed employees to consider information such as the amount of the check, whether the check is “drawn off a local bank or out-of-market,” whether the customer has sufficient “compensating funds” in their account, when the account was opened, the number of times the account was overdrawn, and the average account balance. (Placing a Reg CC Hold, PageID.601.) For checks over $1,000.00, the policy instructed employees to conduct a “deeper dive.” (Id.) Another policy, the Negotiable Instrument Decision Making Guide, provided a list of questions to ask “[w]hen a customer presents an item that seems out of the ‘norm’ or does not seem ‘reasonable’ for what the Bank knows about the customer, the customer’s account history and total customer relationship[.]” (Negotiable Instrument Decision Making Guide, PageID.625.) It instructed the employee to “engage the customer in a discussion” in order to learn more information that would “protect the customer and the Bank from loss.” (Id.) The employee should tell such customers that Horizon was “aware of many different types of fraud happening around us,” and the employee should ask questions like the following: “Are you familiar with the person

or business that sent you this check?” and “Were you advised that you won a sweepstakes or lottery?” (Id.) If the employee had “[r]eason to doubt collectability,” the bank could place a hold to delay the availability of funds from the deposit. (Id.) Betker questioned whether Branscumb’s check was authentic, telling Branscumb there was “so much different fraud going on” and that Branscumb “should be aware of things like that.” (Branscumb Dep. 33.) Branscumb explained that the check was a settlement check that she had received from her lawyer’s office. (Id. at 34.) Betker responded, “[W]ell, you do know if it came in the mail it’s not real, right?” (Id.) Branscumb went ahead and deposited the check. Betker said that $225 would be available to Branscumb immediately, $5,300 would be available on March 25,

2022, and the remaining $17,091.14 would be available on April 1, 2022. (Id. at 34, 38-39.) These conditions were documented in a “deposit hold notice” entered that same day. (Deposit Hold Notice, ECF No. 54-7; Kearney Dep. 16, ECF No. 56-9.) Also, these conditions were consistent with the terms of Branscumb’s account for large check deposits, i.e., deposits greater than $5,525 on a single day. (See Deposit Account Terms, ECF No. 54-8, PageID.450.) Those terms provided that Horizon would make the first $225 of a deposit available the same business day, but “[i]n some cases,” the availability of remaining funds would be delayed. (Id.) Those circumstances included the following: We believe a check you deposited will not be paid. You deposit checks totaling more than $5,525 in one day. . . . You have overdrawn your account repeatedly in the last six months.

(Id.) B. Horizon Suspends Branscumb’s Debit Card & Savings Account (March 25, 2022) On March 25, 2022, Danyele English, a deposit operations clerk for Horizon, reviewed automatically generated, daily “close reports” and saw that Branscumb’s savings account had been negative for over 25 days. (English Dep. 8-9, ECF No. 54-22; see Account Statements, PageID.471, 474 (showing negative account balances on February 28 and March 22).) She confirmed that the account was still negative, so she suspended both the savings account and Branscumb’s debit card, which was tied to that account.1 (Id. at 9-10, 15.) English had never met, seen, or spoken with Branscumb and did not know her race. (Id. at 14.) C. Horizon Refuses Branscumb’s Request to Withdraw $5,000 (March 26, 2022) On Saturday, March 26, 2022, Branscumb called the Niles Road branch and confirmed with Ciara Kearney, a teller at that branch, that $5,300 would be available for withdrawal. (Kearney Dep. 18.) Branscumb’s friend Shameka Marlowe took her to a Horizon branch located in Benton Harbor, Michigan, to withdraw some of those funds. (Branscumb Dep. 40-41.) Marlowe pulled up to the drive-through window at the bank. (Id. at 43.) Branscumb was in the passenger seat. (Id. at 44.) Branscumb gave her driver’s license and debit card to Michelle Shuey, a customer service representative who was working the teller window that day. Branscumb said that she wanted to make a withdrawal for $5,000. (Id. at 45.) Shuey left the window for about five minutes. (Id. at 48.)

1 Branscumb deposited the settlement check to her checking account, so that deposit did not impact her savings account. (See Account Statements, PageID.473.) While away from the window, Shuey checked Branscumb’s checking account and spotted some “red flags” in Branscumb’s request. (Shuey Dep. 13-14, ECF Nos. 54-17, 56-10.) The withdrawal request was for a “larger” amount. (Id. at 13.) It was based on a recent check deposit that was unlike any other that Branscumb had ever deposited to her account. (Id. at 14.) If the check was returned, Branscumb would not have funds to cover the withdrawal. (Id.) Shuey also

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Branscumb v. Horizon Bancorp, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/branscumb-v-horizon-bancorp-inc-miwd-2024.