Ciera Mayes v. Goldman Sachs Bank USA

CourtIndiana Court of Appeals
DecidedMarch 27, 2024
Docket23A-CC-01604
StatusPublished

This text of Ciera Mayes v. Goldman Sachs Bank USA (Ciera Mayes v. Goldman Sachs Bank USA) is published on Counsel Stack Legal Research, covering Indiana Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ciera Mayes v. Goldman Sachs Bank USA, (Ind. Ct. App. 2024).

Opinion

FILED Mar 27 2024, 8:45 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana Ciera Mayes, Appellant-Defendant

v.

Goldman Sachs Bank USA, Appellee-Plaintiff

March 27, 2024 Court of Appeals Case No. 23A-CC-1604 Appeal from the Dearborn Superior Court The Honorable Jonathan Neil Cleary, Judge Trial Court Cause No. 15D01-2107-CC-318

Opinion by Chief Judge Altice Judges Weissmann and Kenworthy concur.

Altice, Chief Judge.

Court of Appeals of Indiana | Opinion 23A-CC-1604 | March 27, 2024 Page 1 of 15 Case Summary [1] Ciara Mayes executed an Installment Loan Agreement (Loan Agreement) with

Goldman Sachs Bank USA (the Bank) for a personal loan. After about six

months of nonpayment, the Bank advised Mayes by letter that it was seeking

collection of $9,235.30 owed on the loan. Mayes thereafter sent a $200 check

and accompanying letter to the Bank, stating that cashing of the check would be

“considered settlement in full” of the still-outstanding balance. Appendix at 80.

The Bank cashed the check. The Bank subsequently filed a breach of contract

action against Mayes on the Loan Agreement, and she counterclaimed,

asserting various claims on the basis that the matter had been settled. The

parties filed respective motions for summary judgment. The trial court

summarily granted the Bank’s motion and entered judgment in favor of the

Bank on its complaint and against Mayes on her counterclaims. Mayes appeals

and raises the following restated issues:

1. Did the Bank, by cashing the $200 check, enter into a settlement agreement with Mayes where the terms of the Loan Agreement provided that it could not be altered or modified except by written instrument and that partial payments received and negotiated would have no effect on the terms of the Loan Agreement?

2. Did Mayes satisfy Indiana’s requirements as provided in Ind. Code § 26-1-3.1-311 for an accord and satisfaction?

3. Was the Bank entitled to summary judgment on its breach of contract claim?

Court of Appeals of Indiana | Opinion 23A-CC-1604 | March 27, 2024 Page 2 of 15 [2] We affirm.

Facts & Procedural History [3] In February 2018, Mayes entered into the Loan Agreement with the Bank, in

which the Bank agreed to lend Mayes the principal sum of $20,000 plus interest,

which she agreed to repay along with, if applicable, late charges, returned

payment charges, and reasonable costs of collection. As is relevant here, the

Agreement contained the following provisions:

7.b. Waivers.

. . . [N]o alteration, amendment or waiver of any provision of this agreement or any other document or agreement relating to the Loan or this Agreement, shall release, modify, amend, waive, extend, change, discharge, terminate or affect your unconditional liability, except to the extent explicitly agreed pursuant to Section 13.

***

13. Amendment.

Except as otherwise provided herein, this Agreement may not be amended, modified or limited except by a written agreement.

21. Partial Payments Marked Payment in Full.

Court of Appeals of Indiana | Opinion 23A-CC-1604 | March 27, 2024 Page 3 of 15 We may process a late payment, a partial payment or a payment marked with any restrictive language. If we do, that action will have no effect on our rights and the restrictive language will have no force or effect.

Id. at 21, 22, 25.

[4] On July 31, 2020, a law firm sent a letter (Collection Letter) to Mayes advising

that it had been retained by the Bank to assist in the collection of funds that she

owed the Bank under the Loan Agreement and stating that the current balance

was $9,235.30. The letter stated:

Please note that unless you dispute said debt, or any portion thereof within thirty (30) days after your receipt of this letter, this firm shall assume the validity of this debt.

Id. at 77. The letter also directed Mayes to “[p]lease contact this law firm to

discuss repayment[.]” Id.

[5] About six months later, on January 18, 2021, Mayes’s attorney sent a letter to

the Bank advising that she had been retained by Mayes “to assist in the matter

of debt relief.” Id. at 80. The letter further stated:

My client disputes the debt. However, in an effort to resolve this matter without filing bankruptcy, I’m enclosing a check for $200.00. If you cash this check for the disputed debt, it will be considered settlement in full. If you do not cash the check, this debt may be included in a bankruptcy. Do not cash this check if you do not want to resolve this account in full.

Court of Appeals of Indiana | Opinion 23A-CC-1604 | March 27, 2024 Page 4 of 15 Id. Enclosed with the letter was a check payable to the Bank in the amount of

$200, and in the memo section of the check was typed “Settlement Marcus 1 for

Ciera”. Id. at 81. The Bank received and processed the check.

[6] On July 14, 2021, the Bank filed a complaint against Mayes, alleging that

Mayes breached the Loan Agreement because she failed to make monthly

installment payments as required. The Bank stated that, pursuant to its

contractual right to accelerate the time for repayment, it was declaring “the

entire balance due,” and it asked the trial court for entry of judgment against

Mayes in the amount of $9,035.30. Appendix at 12. The complaint attached

and incorporated an Affidavit of Debt,2 which in turn attached exhibits,

including the Loan Agreement and account statements. The Affidavit of Debt

indicated that the loan had been “charged-off” in May 2020 but that a $200

payment on the loan had posted on January 27, 2021. Id. at 13.

[7] Mayes filed an answer, denying that she had failed to make payments and was

in default. She asserted eight affirmative defenses, including that the Bank

received “partial and/or total satisfaction with respect to the damages

complained of . . . and the settlement prevents them from asserting this claim.”

Id. at 47. In addition, Mayes asserted counterclaims for breach of contract,

1 “Marcus” is another name for the Bank, as the Loan Agreement sometimes identifies the lender as “Marcus: By Goldman Sachs.” Appendix at 16. 2 The Affidavit of Debt indicated that interest and fees, permissible under the Loan Agreement, were no longer being charged to the account and that the Bank was not seeking attorney’s fees or post-judgment interest.

Court of Appeals of Indiana | Opinion 23A-CC-1604 | March 27, 2024 Page 5 of 15 criminal harassment under Ind. Code § 35-45-2-2, and treble damages pursuant

to Ind. Code § 34-24-3-1 for violation of Ind. Code Article 35-43. 3 The

counterclaims were grounded in allegations that Mayes “settled with [the

Bank]” because it “accepted payment for a disputed debt and resolved this

account,” and it was “suing on a debt that had been satisfied” and thereby was

“attempting to collect on a debt twice.” Id. at 48-49.

[8] The Bank filed an answer, denying all counterclaims, and later filed a motion to

dismiss the counterclaims. The motion to dismiss asserted that Mayes’s

tendered check for $200 did not modify or alter the Loan Agreement’s terms. It

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Ciera Mayes v. Goldman Sachs Bank USA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ciera-mayes-v-goldman-sachs-bank-usa-indctapp-2024.