Crow v. Citibank, NA

CourtUnited States Bankruptcy Court, N.D. West Virginia
DecidedFebruary 25, 2025
Docket5:24-ap-00013
StatusUnknown

This text of Crow v. Citibank, NA (Crow v. Citibank, NA) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, N.D. West Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crow v. Citibank, NA, (W. Va. 2025).

Opinion

No. 5:24-ap-00013 Doc 32 Filed 02/25/25 Entered 02/25/25 16:43:08 Page 1 of 7

q prs eee. LZZ=—_" ‘SS we «=—- David L. Bissett United States Bankruptcy Judge IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF WEST VIRGINIA In re: ) ) LORRY LEE CROW, ) ) Case No. 24-bk-00314 Debtor. ) Chapter 7 oo) ) LORRY LEE CROW and ) MARTIN P. SHEEHAN, Trustee, ) ) Plaintiffs, ) ) Vv. ) Adversary No. 24-ap-00013 ) CITIBANK, N.A., ) ) Defendant. ) oo) MEMORANDUM OPINION Pending before the Court is a motion for summary judgment. Lorry Crow and Martin P. Sheehan (the “Plaintiffs”) seek summary judgment as to Count I of their Complaint against Citibank, N.A. (the “Defendant”) for alleged violations of the West Virginia Consumer Credit and Protection Act (the “WVCCPA”), W. Va. Code § 46A-2-128(e). Specifically, the Plaintiffs assert that the Defendant unlawfully continued debt collection efforts despite recetving notice that Lorry Crow was represented by counsel. The Defendant contends that the notice of representation was not effective because Ms. Crow did not send it to the Defendant’s registered agent pursuant to the requirement of W. Va. Code § 46A-2-128(e). For the reasons stated herein, the Court will deny the Plaintiffs’ Motion for Summary Judgment and grant summary judgment as to Count I of the Plaintiffs’ Complaint in favor of the Defendant.

I. STANDARD OF REVIEW Federal Rule of Civil Procedure (“Rule”) 56, made applicable to this proceeding by Federal Rule of Bankruptcy Procedure 7056, provides that summary judgment is only appropriate if the movant demonstrates “that there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). A party seeking summary judgment must make a prima facie case by showing: first, the apparent absence of any genuine dispute of material fact; and second, the movant’s entitlement to judgment as a matter of law on the basis of undisputed facts. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). The movant bears the burden of proof to establish that there is no genuine dispute of material fact. Celotex Corp. v. Catrett, 477 U.S. 317, 325 (1986). Demonstrating an absence of any genuine dispute as to any material fact satisfies this burden. Id. at 323. Material facts are those necessary to establish the elements of the cause of action. Anderson, 477 U.S. at 248. Thus, the existence of a factual dispute is material — thereby precluding summary judgment — only if the disputed fact is determinative of the outcome under applicable law. Shaw v. Stroud, 13 F.3d 791, 798 (4th Cir. 1994). A movant is entitled to judgment as a matter of law if “the record as a whole could not lead a rational trier of fact to find for the non-movant.” Williams v. Griffin, 952 F.2d 820, 823 (4th Cir. 1991) (citation omitted); see also Anderson, 477 U.S. at 248. If the moving party shows that there is no genuine dispute of material fact, the nonmoving party must set forth specific facts that demonstrate the existence of a genuine dispute of fact for trial. Celotex Corp.,477 U.S. at 322-23. The court is required to view the facts and draw reasonable inferences in the light most favorable to the nonmoving party. Shaw, 13 F.3d at 798. However, the court’s role is not “to weigh the evidence and determine the truth of the matter but to determine whether there is a genuine issue for a trial.” Anderson, 477 U.S. at 249. Nor should the court make credibility determinations. Sosebee v. Murphy, 797 F.2d 179, 182 (4th Cir. 1986). If no genuine issue of material fact exists, the court has a duty to prevent claims and defenses not supported in fact from proceeding to trial. Celotex Corp., 477 U.S. at 317, 323-24. II. BACKGROUND In March of 2024, Lorry Crow held two unpaid consumer accounts with the Defendant. At some point before March of 2024, the outstanding balances triggered the Defendant’s debt collection efforts. On or about March 15, 2024, Ms. Crow sought legal representation in relation to the debts owed. On March 15, 2024, Ms. Crow’s counsel sent two letters to the Defendant, one to its principal place of business and one to the address listed on Ms. Crow’s credit report, notifying it that he represented Ms. Crow and requesting all further communications be directed to him. On March 19, 2024, the Defendant received one of the two letters. On March 20, 2024, the Defendant sent Ms. Crow a response letter acknowledging receipt of Ms. Crow’s credit reporting dispute but contending it did not have sufficient information regarding Ms. Crow’s accounts to investigate the dispute. On March 22, 2024, the Defendant received the second letter. And again, on March 27, 2024, the Defendant sent Ms. Crow’s counsel a letter in response acknowledging its receipt of Ms. Crow’s credit reporting dispute but contending it did not have sufficient information regarding the accounts to investigate the dispute. Between March 26, 2024, and May 6, 2024, the Plaintiffs assert that the Defendant contacted Ms. Crow approximately eighty-eight times in violation of W. Va. Code § 46A-2-128(e). As a result, on May 6, 2024, Ms. Crow’s counsel sent two letters serving as a “Notice of Right to Cure” for each account pursuant to W. Va. Code § 46A-5-108. Unlike the previous letters, these letters were sent to the Defendant’s principal place of business and to its registered agent. On May 20, 2024, one of the letters was received by the Defendant’s registered agent. The other letter was received by the Defendant at its principal place of business on May 10, 2024, and by its registered agent on June 13, 2024. On May 21, 2024, Ms. Crow’s accounts were coded cease and desist. On June 20, 2024, the 45-day statutory period for the Defendant to respond to the Right to Cure Notice expired without the Defendant offering to cure the alleged violations. On July 12, 2024, the Plaintiffs initiated this adversary proceeding against the Defendant, alleging violations of the WVCCPA and seeking statutory damages, cancellation of debts, and attorneys’ fees in Count I and alleging violations of the Telephone Consumer Protection Act (the “TCPA”), 47 U.S.C. § 227 and seeking statutory and punitive damages in Count II. The Plaintiffs moved for summary judgment, specifically relating to Count I of the Complaint and the WVCCPA allegations, arguing that the Defendant’s continued communications constituted violations of the WVCCPA and that notice sent to the Defendant’s principal place of business was proper and effective adequate notice. In response, the Defendant argued that the Plaintiffs’ notice was legally ineffective because it was not sent to its registered agent, as required by W. Va. Code § 46A-2- 128(e). In reply, the Plaintiffs argued that W. Va. Code § 46A-2-128(e) should be liberally construed to favor consumers, which should render their notice effective despite not having been sent to the registered agent. 1 III.

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Crow v. Citibank, NA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crow-v-citibank-na-wvnb-2025.