Edge v. Infinity Federal Credit Union

CourtSuperior Court of Maine
DecidedAugust 21, 2023
DocketCUMcv-23-00038
StatusUnpublished

This text of Edge v. Infinity Federal Credit Union (Edge v. Infinity Federal Credit Union) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edge v. Infinity Federal Credit Union, (Me. Super. Ct. 2023).

Opinion

STATE OF MAINE BUSINESS & CONSUMER COURT CUMBERLAND, ss. CIVIL ACTION DOCKET NO. BCD-CIV-2023-00038

CATHERINE EDGE, on behalf of ) herself and all others similarly situated, ) ) Plaintiff, ) ) ORDER DENYING IN PART ) AND GRANTING IN PART v. ) DEFENDANT’S MOTION TO ) DISMISS ) INFINITY FEDERAL CREDIT UNION, ) ) Defendant. )

BACKGROUND

Defendant Infinity Federal Credit Union (the “Defendant”) has brought a Motion to

Dismiss the Class Action Complaint filed by Plaintiff Catherine Edge (the “Plaintiff”). Plaintiff,

on behalf of herself and all other similarly situated, filed suit against Defendant alleging breach of

contract, unjust enrichment, and violation of the Maine Unfair Trade Practices Act (“MUTPA”),

5 M.R.S. §§ 205-A-214, flowing from Defendant’s fee practices. 1 Plaintiff filed her opposition to

Defendant’s Motion to Dismiss on August 4, 2023, and Defendant replied on August 18, 2023.

The Court decides Defendant’s motion based on its review of Plaintiff’s Class Action Complaint,

the exhibits attached thereto, and the motion papers submitted by the parties. M.R. Civ. P. 7(b)(7).

For the foregoing reasons, Defendant’s Motion to Dismiss is DENIED IN PART and GRANTED

IN PART.

MOTION TO DISMISS STANDARD

A motion to dismiss under Maine Rule of Civil Procedure 12(b)(6) “tests the legal

1 Plaintiff has since expressly declined to pursue her unjust enrichment claim. Pl.’s Opp’n to Def.’s Mot. Dismiss 16 n.8.

1 sufficiency of the complaint and does not probe the merits of the underlying case.” Carey v. Bd.

of Overseers of the Bar, 2018 ME 119, ¶ 19, 192 A.3d 589 (internal quotation marks omitted). In

reviewing a motion to dismiss, courts must “consider the facts in the complaint as if they were

admitted.” Bonney v. Stephens Mem. Hosp., 2011 ME 46, ¶ 16, 17 A.3d 123 (citing Saunders v.

Tisher, 2006 ME 94, ¶ 8, 902 A.2d 830). The complaint is viewed “in the light most favorable to

the plaintiff to determine whether it sets forth elements of a cause of action or alleges facts that

would entitle the plaintiff to relief pursuant to some legal theory.” Id. (quotation marks omitted).

Generally, a court may consider only the pleadings on a motion to dismiss. Moody v. State

Liquor & Lottery Comm’n, 2004 ME 20, ¶¶ 8-9, 843 A.2d 43. However, official public documents,

documents central to the plaintiff’s complaint, and the documents referred to therein may also be

considered in a ruling on a motion to dismiss without converting the motion into a motion for

summary judgment when the documents’ authenticity is not challenged. Id. ¶ 10. Here, Plaintiff

attached copies of the Membership Agreement and Disclosures that she entered into with

Defendant, a schedule of fees copied from Defendant’s website 2, and a copy of Defendant’s

Courtesy Pay Overdraft Services Disclosure. Because Plaintiff attached these documents to her

Class Action Complaint, they are properly considered by the Court in deciding Defendant’s

Motion to Dismiss.

FACTUAL ALLEGATIONS

Defendant is a federal credit union that provides retail banking services to its members,

including Plaintiff. Compl. ¶ 6. Plaintiff is an individual who maintained a checking account with

2 Plaintiff submitted one copy of Defendant’s fee schedule from 2023, Compl. Ex. B, and another from 2021, Pl.’s Opp’n to Def.’s Mot. Dismiss Ex. 9 [hereinafter “Fee Schedule”]. The Court relies on the 2021 version for the purpose of deciding Defendant’s Motion to Dismiss. Even though that version was not attached to the Class Action Complaint, it is specifically referred to therein and is otherwise integral to Plaintiff’s claims. See Moody, 2004 ME 20, ¶¶ 8-9, 843 A.2d 43.

2 Defendant at all times relevant to this lawsuit. Compl. ¶ 5. Plaintiff was provided Defendant’s

Membership Agreement and Disclosures (the “Agreement”) when she became one of Defendant’s

members. Compl. Ex. A.

Relevant here, the Agreement provides: “[i]f an item is presented without sufficient funds

in your account to pay it, we may, at our discretion, pay the item (creating an overdraft) or return

the item ([insufficient funds]).” Compl. ¶¶ 21, 23; Compl. Ex. A, at 9. The Agreement then

references Defendant’s Fee Schedule. The Fee Schedule listed a $35 fee that was triggered when

Defendant paid an item presented without sufficient funds on account, and a $32 fee triggered

when an item presented without sufficient funds on account was returned. Fee Schedule, at 1.

Defendant construes the Agreement to permit it to charge a fee each time an “item” is

“presented” to it for payment. Compl. ¶¶ 24-27. For example, Defendant will charge a fee when

an item is first presented but it is determined that the account contained insufficient funds, as well

as a second fee when the item is re-presented or reprocessed (e.g., when a merchant initiates a

request for payment through the Automated Clearing House network after a customer uses her

debit card to pay for goods or services). Compl. ¶ 14. on or around February 8, 2019, Plaintiff was

assessed multiple fees for the same transaction. Compl. ¶ 36. The same occurred on or around

February 15, 2019, and December 15, 2021. Compl. ¶¶ 37-38.

DISCUSSION

The Court addresses Defendant’s Motion to Dismiss in the context of Plaintiff’s causes of

action for breach of contract and violation of the MUTPA, respectively.

I. Whether Plaintiff’s Class Action Complaint adequately states a claim for breach of contract.

Plaintiff interprets the Agreement to permit Defendant to charge one overdraft or

insufficient funds fee per “item.” Compl. ¶ 34. According to Plaintiff, Defendant’s fee practices

3 constitute a breach of the Agreement. Defendant, however, interprets the Agreement to permit it

to charge either the overdraft or insufficient funds fee each time an “item” is “presented” for

payment, no matter whether by the account holder or by a third-party service provider. Def.’s Mot.

Dismiss 9. This is a “true breach of contract” dispute going to the meaning of the Agreement’s

terms that is not pre-empted by federal law. See Lambert v. Navy Federal Credit Union, No. 1:19-

cv-103-LO-MSN, 2019 WL 3843064, at *2 (E.D. Va. Aug. 14, 2019). Determination of whether

a contract or agreement is ambiguous is a question of law. Acadia Ins. Co. v. Buck Const. Co.,

2000 ME 154, ¶ 8, 756 A.2d 515. Contractual language is ambiguous when it is “reasonably

susceptible to different interpretations.” Id. ¶ 9.

The Court observes that this case is similar to Churchill v. Bangor Savings Bank, and

Plaintiff’s opposition to Defendant’s Motion to Dismiss understandably leans heavily on this

Court’s determination in Churchill that the word “item” as used throughout the Agreement is

ambiguous. See Churchill v. Bangor Savings Bank, No. BCD-CIV-2021-00027, 2021 WL

3700676, at *4 (Me. B.C.D. Aug. 12, 2021). Here, as in Churchill, it is unclear whether the

Agreement authorizes Defendant to charge members more than one fee per item. Like the contract

in Churchill, the word “item” is not specifically defined within the Agreement. Compl. Ex. A, at

3-4. When the language of the Agreement is paired with the Fee Schedule, the intent of the parties

regarding multiple presentments is unclear. As illustrated by the parties’ briefs, the word “item”

as it is used within the Agreement is reasonably susceptible to different interpretations. On the

record before the Court at the Motion to Dismiss stage, the Agreement’s language appears

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Related

English v. General Electric Co.
496 U.S. 72 (Supreme Court, 1990)
School Union No. 37 v. United National Insurance
617 F.3d 554 (First Circuit, 2010)
Moody v. State Liquor & Lottery Commission
2004 ME 20 (Supreme Judicial Court of Maine, 2004)
Saunders v. Tisher
2006 ME 94 (Supreme Judicial Court of Maine, 2006)
Acadia Insurance Co. v. Buck Construction Co.
2000 ME 154 (Supreme Judicial Court of Maine, 2000)
Seabury Housing Associates v. Home Insurance
695 F. Supp. 1244 (D. Maine, 1988)
Bonney v. Stephens Memorial Hospital
2011 ME 46 (Supreme Judicial Court of Maine, 2011)
Puritan Medical Products Company LLC v. Copan Italia S.P.A.
2018 ME 90 (Supreme Judicial Court of Maine, 2018)
Seth T. Carey v. Board of Overseers of the Bar
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Bluebook (online)
Edge v. Infinity Federal Credit Union, Counsel Stack Legal Research, https://law.counselstack.com/opinion/edge-v-infinity-federal-credit-union-mesuperct-2023.