Delapaz v. Bank of America, N.A.

CourtDistrict Court, S.D. California
DecidedApril 15, 2025
Docket3:21-cv-01660
StatusUnknown

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

Bluebook
Delapaz v. Bank of America, N.A., (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 MICHAEL DELAPAZ, Case No.: 21CV1660-GPC(MSB)

12 Plaintiff, ORDER DENYING PLAINTIFF’S 13 v. MOTION TO LIFT STAY AS TO HIS INDIVIDUAL ACTION 14 BANK OF AMERICA, N.A. and DOES 1 through 10, inclusive, 15 Defendant. 16

17 Plaintiff Michael Delapaz (“Plaintiff”) filed a motion to lift the stay as to his 18 individual action. (Dkt. No. 10.) Defendant Bank of America, N.A. (“Defendant or 19 “BANA”) filed an opposition and Plaintiff replied. (Dkt. Nos. 14, 15.) 20 Background 21 On September 21, 2021, the case was removed from state court. (Dkt. No. 1.) 22 Plaintiff alleges he was issued an account from BANA for the deposit of benefits from 23 the California Employment Development Department (“EDD”). (Dkt. No. 1-3, Compl. ¶ 24 5.) Because BANA failed to properly maintain Plaintiff’s personal information 25 regarding the account, unknown individuals accessed his account and personal 26 information, and withdrew his funds from ah ATM machine. (Id. ¶¶ 7-10.) Even though 27 Plaintiff disputed the unauthorized transaction with BANA and reported it to the police, 28 1 he claims that BANA did not conduct a reasonable investigation, did not refund the funds 2 taken from his account, and as a result, he was unable to afford items he needed to buy. 3 (Id. ¶¶ 12-16.) Plaintiff brings causes of action for violations of the California Customer 4 Records Act (“CRA”) under Cal. Civil Code section 1798.80 et seq., the California 5 Consumer Privacy Act (“CCPA”) pursuant to Cal. Civil Code section 1798.100 et seq., 6 the Electronic Funds Transfer Act (“EFTA”), 15 U.S.C. § 1693 et seq., and negligence. 7 On the same day when the case was removed, BANA filed a notice of related case 8 with a multidistrict litigation involving similar issues in In re Bank of Amer. Cal. 9 Unemployment Benefits Litig., 21-MD-2992-LAB-MSB (“MDL”). (Dkt. No. 2.) On 10 October 4, 2021, the case was transferred pursuant to the Low Number Rule and it 11 became a member case of 21-MD-2992-LAB-MSB. (Dkt. No. 7.) On October 14, 2021, 12 the Court sua sponte stayed the case pending resolution of the related MDL case 13 concluding, “[o]n a party’s motion after the stay is lifted, the Court will consider applying 14 its rulings in that multidistrict litigation to this action via nonmutual collateral estoppel or 15 any other applicable theory.” (Dkt. No. 5.) On April 8, 2024, the case was transferred to 16 the undersigned judge. (Dkt. No. 9.) On February 13, 2025, Plaintiff filed a motion to 17 lift stay which is fully briefed. (Dkt. Nos. 10, 14, 15.) 18 The MDL case arises from Class Action Plaintiffs and Individual Plaintiffs’ 19 claims against BANA for violations of the Electronic Funds Transfer Act and related 20 causes of action during its administration of the electronic benefits payment system for 21 California’s EDD during the COVID-19 pandemic. (See Case No. 21-MD-2992, Dkt. 22 No. 406, Third Amended Master Consolidated Complaint (“TAMCC”).) Early on in the 23 MDL proceedings, the Court held a case management conference on July 19, 2021 to 24 address the organizational structure and administrative process of managing the MDL. 25 (Id., Dkt. Nos. 16, 48, 49, 55.) In the Court’s order following the case management 26 conference, the Court set dates for the Class Plaintiffs and Individual Plaintiffs in the 27 28 1 consolidated pleading to proceed and stayed any member cases that were not included in 2 the consolidated pleading. (Id., Dkt. No. 48 at 2.) When new individual plaintiffs began 3 filing complaints with similar causes of action arising from the same underlying factual 4 allegations against BANA, the Court stayed them pending resolution of the MDL case. 5 (See id., Dkt. No. 85.) Further, on September 17, 2024, litigation of the Individual 6 Plaintiffs in the master consolidated complaint was stayed until a ruling on the class 7 certification motion. (Dkt. No. 338.) 8 Class Plaintiffs and BANA have been actively engaged in discovery since May 9 2023. Fact discovery has closed and the parties are currently engaged in expert discovery 10 which is set to close on May 16, 2025. (See Dkt. No. 447.) On March 28, 2025, the 11 Court granted Defendant’s motion to stay the case pending the Supreme Court review of 12 Lab’y Corp. of Am. Holdings v. Davis, No. 24-0304, which will address issues affecting 13 the class certification in this case. (Dkt. No. 448.) A ruling is expected at the end of June 14 2025. However, in that order, the Court denied the motion to stay as to the deadline to 15 complete expert discovery and issues related to expert discovery. (Id.) 16 Discussion 17 A. Motion to Lift Stay 18 The “power to stay proceedings is incidental to the power inherent in every court 19 to control the disposition of the causes on its docket with economy of time and effort for 20 itself, for counsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 248, 254 (1936). 21 “[T]he same court that imposes a stay of litigation has the inherent power and discretion 22 to lift the stay.” Canady v. Erbe Elektromedizin GmbH, 271 F. Supp. 2d 64, 74 (D.D.C. 23 2002); Thomas v. Home Depot USA Inc., No. C06-02705 MJJ, 2007 WL 2140917, at *1 24 (N.D. Cal. Jul. 25, 2007) (“The power to grant a stay includes the inherent power and 25 26 27 1 Member cases are those individual plaintiffs’ complaint that were not included in the consolidated pleading filed on August 17, 2021. (Case No. 21-md-2992, Dkt. No. 48 at 2.) In other words, member 28 1 discretion to lift that stay.”). A court may lift the stay when “[p]etitioners no longer 2 satisfy the standard for issuance of a stay.” Ala. Survival v. Surface Transp. Bd., 704 3 F.3d 615, 616 (9th Cir. 2012). In other words, “[w]hen circumstances have changed such 4 that the court's reasons for imposing the stay no longer exist or are inappropriate, the 5 court may lift the stay.” Canady, 271 F. Supp. 2d at 74; Ho Keung Tse v. Apple Inc., No. 6 C 06–06573 SBA, 2010 WL 1838691, at *1 (N.D. Cal. 2010) (citing Canady, 271 F. 7 Supp. 2d at 74) (“A court may lift the stay if the circumstances supporting the stay have 8 changed such that the stay is no longer appropriate.”) 9 When determining whether to stay an action, the court must weigh the following 10 competing interests: (1) “the possible damage which may result from the granting of a 11 stay;” (2) “the hardship or inequity which a party may suffer in being required to go 12 forward;” and (3) “the orderly course of justice measured in terms of the simplifying or 13 complicating of issues, proof, and questions of law which could be expected to result 14 from a stay.” CMAX, Inc. v. Hall, 300 F.2d 265, 268 (9th Cir. 1962) (citing Landis, 299 15 U.S. at 254–55). The Court considers whether any changed circumstances justify lifting 16 the stay based on the Landis factors. 17 1. Balance of Hardship Between the Parties 18 The Court must balance the “possible damage [to Plaintiffs] which may result from 19 the granting of a stay,” with “the hardship or inequity which [Defendants] may suffer in 20 being required to go forward.” CMAX, 300 F.2d at 268. 21 Plaintiff argues he will be prejudiced and suffer undue hardship because the case 22 has been delayed for almost three years so he has not been able to pursue his individual 23 claims, has not had access to the funds wrongfully taken from his bank account, and the 24 continued delay has created an undue hardship. (Dkt. No. 10 at 2-32; Dkt. No.

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Related

Landis v. North American Co.
299 U.S. 248 (Supreme Court, 1936)
Canady v. Erbe Elektromedizin GmbH
271 F. Supp. 2d 64 (District of Columbia, 2002)
Lockyer v. Mirant Corp.
398 F.3d 1098 (Ninth Circuit, 2005)
Cmax, Inc. v. Hall
300 F.2d 265 (Ninth Circuit, 1962)
Dhine v. Slattery
3 F.3d 613 (Second Circuit, 1993)
In re Weinstein
271 F. 5 (S.D. New York, 1920)

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Delapaz v. Bank of America, N.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/delapaz-v-bank-of-america-na-casd-2025.