Conti v. Bank of America

CourtDistrict Court, D. Hawaii
DecidedMarch 28, 2025
Docket1:24-cv-00182
StatusUnknown

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

Bluebook
Conti v. Bank of America, (D. Haw. 2025).

Opinion

UNITED STATES DISTRICT COURT

DISTRICT OF HAWAII

VINCENT CONTI, CIV. NO. 24-00182 LEK-KJM

Plaintiff,

vs.

BANK OF AMERICA,

Defendant.

ORDER GRANTING IN PART AND DENYING IN PART DEFENDANT’S MOTION TO DISMISS COMPLAINT [DOC. 1-1] FOR FAILURE TO STATE A CLAIM PURSUANT TO FED. R. CIV. P. 12(B)(6)

On July 19, 2024, Defendant Bank of America, N.A. (“Defendant”) filed their Motion to Dismiss Complaint [Doc. 1-1] for Failure to State a Claim Pursuant to Fed R. Civ. P. 12(b)(6) (“Motion”). [Dkt. no. 13.] Pro se Plaintiff Vincent Conti (“Plaintiff”) did not file a response to the Motion. The Court finds this matter suitable for disposition without a hearing pursuant to Rule LR7.1(c) of the Local Rules of Practice for the United States District Court for the District of Hawaii (“Local Rules”). Defendant’s Motion is hereby granted in part and denied in part for the reasons set forth below. The Motion is granted insofar as Plaintiff’s complaint is dismissed in its entirety and insofar as some portions of the Complaint are dismissed with prejudice. The Motion is denied insofar as the remaining portions of the Complaint are dismissed without prejudice. BACKGROUND Plaintiff filed his Complaint in the State of Hawai`i Circuit Court of the Second Circuit (“the state court”) on March 15, 2024. [Defendant’s Notice of Removal of Action, (“Notice of Removal”), filed 4/22/24 (dkt. no. 1), Exh. A

(Complaint).] On April 22, 2024, Defendant removed the action this district court based on federal question jurisdiction. [Notice of Removal at ¶ 11.] During the period relevant to this case, Defendant was the holder of one of Plaintiff’s vehicle loans. See Complaint at ¶¶ 1, 5. Plaintiff alleges Defendant violated the Fair Credit Reporting Act (“FRCA”), Title 15 United States Code Section 1651, and the “Hawai`i Consumer Protection Act” by failing to grant him a payment deferral. [Id. at ¶ 4.] Plaintiff alleges that, on or about August 17, 2023, he submitted a written request seeking a four-month deferral of his loan due to the Maui wildfires. [Id. at ¶¶ 1-2.] Plaintiff alleges that “Maui, Hawaii, had been declared a federal disaster

area,” and “Hawaii Governor Josh Green had directed all lenders to defer payments to all parties in the disaster area.” [Id. at ¶¶ 2-3.] Plaintiff alleges that, on October 3, 2023, he received a letter stating Defendant “had made numerous attempts to contact Plaintiff regarding payment on one of [his] auto loans.” [Id. at ¶ 5.] Plaintiff alleges that, on October 4, 2023, he contacted one of Defendant’s collection agents. Plaintiff alleges Defendant’s collection agent acknowledged that Plaintiff’s August 17, 2023 letter requesting a deferral was received on August 22, 2023, the letter was noted in Plaintiff’s file, and that there was no record of Defendant responding. Plaintiff alleges that Defendant’s collection agent had no

records of Defendant attempting to contact Plaintiff by telephone or email. According to Plaintiff, Defendant’s collection agent acknowledged Defendant had a policy of deferring payments in disaster areas, and that Plaintiff’s request was timely submitted, but the collection agent informed Plaintiff that Defendant would not defer any of Plaintiff’s payments. [Id. at ¶¶ 6-9.] Further, Plaintiff alleges that Defendant’s “collection agents made numerous false statements about the deferral extension in an attempt to collect a debt” and that Defendant “made negative reports to the Credit Reporting Agencies.” [Id. at ¶ 11.] In the instant case, Plaintiff is seeking $25,000 in damages and an order requiring

Defendant “to retract and remove any negative [reports] submitted to Credit Reporting Agencies.” [Id. at PageID.9.] In the instant Motion, Defendant asks this Court to dismiss the Complaint pursuant to Rule 12(b)(6) of the Federal Rules of Civil Procedure. [Motion at 2.] Defendant argues that Plaintiff fails to state a plausible claim for relief and that the Complaint should be dismissed with prejudice. [Motion, Mem. in Supp. at 1-2.] Defendant argues: 1) Plaintiff fails to allege facts that, if proven, would establish that Defendant violated obligations under the FCRA; 2) Plaintiff fails to allege he complied with the steps necessary to bring a claim under the FCRA; 3) Plaintiff fails to allege an inaccuracy in credit

reporting; 4) Plaintiff’s claim under the Hawai`i consumer protection statutes is expressly preempted; and 5) Plaintiff’s has failed to state an unfair or deceptive acts or practices (“UDAP”) claim. [Id. at 5-10.] DISCUSSION I. Construction of Plaintiff’s Claims Plaintiff brings this action pursuant to the FRCA, Title 15 United States Code Section 1651, and the “Hawaii Consumer Protection Code,” which Plaintiff also refers to as the “Hawaii Consumer Protection Act.” [Complaint at ¶¶ 4, 10, 11.] The asserted authority for Plaintiff’s FRCA claim, Section 1651, is titled “Procedure for timely settlement of estates of

decedent obligors.” Because Plaintiff’s cited statute is unrelated to the factual allegations and the asserted claim in Plaintiff’s Complaint, this Court instead liberally construes Plaintiff’s Complaint as bringing claims pursuant to Title 15 United States Code Section 1681s-2, titled “Responsibilities of furnishers of information to consumer reporting agencies.”1 See, e.g., Erickson v. Pardus, 551 U.S. 89, 94 (2007) (per curiam) (“A document filed pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by

lawyers.” (citation and internal quotation marks omitted)). However, the purpose of the FCRA is “to ensure fair and accurate credit reporting, promote efficiency in the banking system, and protect consumer privacy.” Safeco Ins. Co. of Am. v. Barr, 551 U.S. 47, 52 (2007) (some citations omitted) (citing 15 U.S.C. § 1681). Even construing Plaintiff’s claims liberally, the FCRA is not intended to regulate conduct such as candor by a lender or regulating debt collection practices. These claims will be liberally construed under their respective legal authorities set forth below. As to Plaintiff’s claims under the “Hawaii Consumer Protection Code”/“Hawaii Consumer Protection Act,” because the

cited statutes do not exist, this Court liberally construes the Complaint as bringing a claim pursuant to Hawai`i Revised

1 Furnishers under the FCRA are “the sources that provide credit information to [credit reporting agencies].” Gorman v. Wolpoff & Abramson, LLP, 584 F.3d 1147, 1153 (9th Cir. 2009). “‘The most common . . . furnishers of information are credit card issuers, auto dealers, department and grocery stores, lenders, utilities, insurers, collection agencies, and government agencies.’” Id. at 1153 n.7 (quoting H.R. Rep. No. 108–263, at 24 (2003)). Statutes Section 480-2, titled “Unfair competition, practices, declared unlawful.” II. Violation of the FCRA Plaintiff alleges Defendant violated the FCRA when it: “failed to respond to the written request for deferred

payments”; “failed to follow its own policy of providing deferred payments to its clients”; and sent a letter “contain[ing] multiple false statements as confirmed by [Defendant’s] agent . . . .” [Complaint at ¶ 10.] Plaintiff further alleges Defendant “made negative reports to the Credit Reporting Agencies,” and Defendant’s collection agents “made numerous false statements . . .

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Safeco Insurance Co. of America v. Burr
551 U.S. 47 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Kearns v. Ford Motor Co.
567 F.3d 1120 (Ninth Circuit, 2009)
Gorman v. Wolpoff & Abramson, LLP
584 F.3d 1147 (Ninth Circuit, 2009)
Cisneros v. Trans Union, LLC
293 F. Supp. 2d 1167 (D. Hawaii, 2003)
Smallwood v. NCsoft Corp.
730 F. Supp. 2d 1213 (D. Hawaii, 2010)
Henson v. Santander Consumer USA Inc.
582 U.S. 79 (Supreme Court, 2017)
Parents for Privacy v. William Barr
949 F.3d 1210 (Ninth Circuit, 2020)
Hawaii Medical Ass'n v. Hawaii Medical Service Ass'n
148 P.3d 1179 (Hawaii Supreme Court, 2006)
Lizza v. Deutsche Bank National Trust Co.
1 F. Supp. 3d 1106 (D. Hawaii, 2014)
Ryan v. Salisbury
382 F. Supp. 3d 1062 (D. Hawaii, 2019)
Davidson v. Kimberly-Clark Corp.
889 F.3d 956 (Ninth Circuit, 2017)
Aargon Agency, Inc. v. Sandy O'Laughlin
70 F.4th 1224 (Ninth Circuit, 2023)
Assurance Wireless USA, L.P. v. Alice Reynolds
100 F.4th 1024 (Ninth Circuit, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
Conti v. Bank of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/conti-v-bank-of-america-hid-2025.