Edmond v. American Educational Services/ National Collegiate Trust

CourtDistrict Court, District of Columbia
DecidedOctober 28, 2010
DocketCivil Action No. 2010-0578
StatusPublished

This text of Edmond v. American Educational Services/ National Collegiate Trust (Edmond v. American Educational Services/ National Collegiate Trust) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Edmond v. American Educational Services/ National Collegiate Trust, (D.D.C. 2010).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

DONALD EDMOND,

Plaintiff, v. Civil Action No. 10-0578 (JDB) AMERICAN EDUCATION SERVICES,

Defendant.

MEMORANDUM OPINION

This matter is before the Court on the Motion to Dismiss Submitted by the Pennsylvania

Higher Education Assistance Agency/American Education Services and on plaintiff’s Motion for

Equitable Relief by Specific Performance. For the reasons stated below, the Court will dismiss

Counts I, II, IV and V of plaintiff’s Amended Complaint and will deny plaintiff’s request for

equitable relief.

I. BACKGROUND

While attending Suffolk University Law School, see Plaintiff’s Amended Complaint

(“Am. Compl.”) ¶ 2, plaintiff obtained a student loan from Bank of America, N.A.; Doris

Muellner, his common-law spouse, id. ¶ 13, was the co-signor. See Motion to Dismiss

Submitted by the Pennsylvania Higher Education Assistance Agency/American Education

Services (“Def.’s Mot.”) [Dkt. #4], Ex. 1 (Cosigned Loan Request/Credit Agreement) at 1 & 2-3

(Note Disclosure Statements) (exhibit numbers designated by the Court).1 The Pennsylvania

1 Ms. Muellner is not a party to this action, and plaintiff lacks standing to bring claims or to demand relief on her behalf.

-1- Higher Education Assistance Agency, d/b/a American Education Services (“AES”), serviced the

loans.2 See Am. Compl. ¶¶ 3-4; Def.’s Mot. at 1-2. According to plaintiff, AES erroneously

reported his accounts delinquent to three credit reporting agencies, Am. Compl. ¶ 13, denied his

request for forbearance, id. ¶ 25, and subjected him and Ms. Muellner to “shrill, harassing and

predatory acts” in its attempt to collect the debt, see id. ¶¶ 22-23. He learned of the alleged

delinquency “when Bank of America notified [Ms.] Muellner that the joint credit card account

she shares with [plaintiff] would be subjected to a reduction in available credit” due to the

delinquent student loan. Id. ¶ 14.

Plaintiff claims that AES breached its covenant of good faith (Count I), violated the Fair

Credit Reporting Act (Count II), defamed him (Count III), engaged in unfair and deceptive

business practices (Count IV), and violated the Fair Debt Collection Practices Act (Count V).

He demands compensatory damages among other relief. See id. at 15.

II. DISCUSSION

A. Dismissal Under Rule 12(b)(6)

The Federal Rules of Civil Procedure require that a complaint contain “‘a short and plain

statement of the claim showing that the pleader is entitled to relief,’ in order to ‘give the

defendant fair notice of what the . . . claim is and the grounds upon which it rests.’” Bell Atl.

Corp. v. Twombly, 550 U.S. 544, 555 (2007) (quoting Conley v. Gibson, 355 U.S. 41, 47 (1957));

accord Erickson v. Pardus, 551 U.S. 89, 93 (2007) (per curiam). Although “detailed factual

2 AES represents that “National Collegiate Trust is a wholly separate entity which is not affiliated with AES.” Def.’s Mot. at 1 n.1. Plaintiff does not supply a separate address or registered agent upon whom service can be effected, and his pleadings do not allege facts pertaining exclusively to National Collegiate Trust. Accordingly, the Court will dismiss National Collegiate Trust as a party defendant to this action.

-2- allegations are not necessary to withstand a Rule 12(b)(6) motion to dismiss, to provide the

grounds of entitle[ment] to relief, a plaintiff must furnish more than labels and conclusions or a

formulaic recitation of the elements of a cause of action.” Twombly, 550 U.S. at 555-56 (internal

quotation marks omitted); see also Papasan v. Allain, 478 U.S. 265, 286 (1986). “To survive a

motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a

claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. __, __, 129 S. Ct. 1937,

1949 (2009) (quoting Twombly, 550 U.S. at 570); Atherton v. District of Columbia Office of the

Mayor, 567 F.3d 672, 681 (D.C. Cir. 2009), cert. denied, 130 S.Ct. 2064 (2010). A complaint is

plausible on its face “when the plaintiff pleads factual content that allows the court to draw the

reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 129 S. Ct. at

1949. However, “the court need not accept inferences drawn by plaintiffs if such inferences are

unsupported by the facts set out in the complaint.” Kowal v. MCI Commc’ns Corp., 16 F.3d

1271, 1276 (D.C. Cir. 1994). Nor must the court accept “a legal conclusion couched as a factual

allegation.” Iqbal, 129 S. Ct. at 1949-50 (citation omitted); see also Aktieselskabet AF 21.

November 2001 v. Fame Jeans Inc., 525 F.3d 8, 17 n.4 (D.C. Cir. 2008) (stating that the court

has “never accepted legal conclusions cast in the form of factual allegations”). “[A] naked

assertion . . . gets the complaint close to stating a claim, but without some further factual

enhancement it stops short of the line between possibility and plausibility.” Twombly, 550 U.S.

at 557.

B. Breach of Covenant of Good Faith (Count I)

“Plaintiff alleges that AES breached its contractual duty to act in good faith by willfully

choosing to inflict harm through deceptive, misleading and predatory behavior and practices it

-3- knew or should have known would cause harm.” Am. Compl. ¶ 31. AES argues that the

complaint not only fails to allege the existence of a contract between the parties but also “fail[s]

to plead any facts that might constitute an agreement or meeting of the minds between the

plaintiff and AES as a loan servicer, and thus cannot establish an implied contract.”

Memorandum of Law in Support of the Motion to Dismiss Submitted by the Pennsylvania

Higher Education Assistance Agency/American Education Services (Incorrectly Identified as

American Educational Services) (“AES Mem.”) at 3. Further, AES asserts that its contract with

the lender, Bank of America, “does not create contractual privity between AES and [p]laintiff.”

Id. at 4.

A claim for breach of contract includes four elements: “(1) a valid contract between the

parties; (2) an obligation or duty arising out of the contract; (3) a breach of that duty; and (4)

damages caused by breach.” Ihebereme v. Capital One, N.A., No. 10-1106, 2010 WL 3118815,

at *3 (D.D.C. Aug. 9, 2010) (quoting Tsinolas Realty Co. v. Mendez, 984 A.2d 181, 187 (D.C.

2009)) (internal quotation marks omitted). “Under District of Columbia law, every contract

contains within it an implied covenant of both parties to act in good faith and damages may be

recovered for its breach as part of a contract action.” Choharis v. State Farm Fire & Cas. Co.,

961 A.3d 1080, 1087 (D.C. 2008) (citing Murray v.

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