Elizabeth Belyea, et al. v. GreenSky, Inc., et al.

CourtDistrict Court, N.D. California
DecidedOctober 28, 2025
Docket3:20-cv-01693
StatusUnknown

This text of Elizabeth Belyea, et al. v. GreenSky, Inc., et al. (Elizabeth Belyea, et al. v. GreenSky, Inc., et al.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elizabeth Belyea, et al. v. GreenSky, Inc., et al., (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 ELIZABETH BELYEA, et al., Case No. 20-cv-01693-JSC

8 Plaintiffs, ORDER RE: MOTION FOR PARTIAL 9 v. SUMMARY JUDGMENT

10 GREENSKY, INC., et al., Re: Dkt. No. 338 Defendants. 11

12 13 Plaintiffs’ certified class action alleges GreenSky, which partners with contractors and 14 banks to provide point-of-sale loans to consumers, charges fees in violation of California 15 consumer protection statutes. (Dkt. No. 216.)1 The Court previously concluded “GreenSky is 16 entitled to summary judgment on all performance fee-related claims” because Plaintiffs agreed to 17 dismiss Plaintiff David Ferguson’s claims related to performance fees and did not present 18 evidence Plaintiff Heidi Barnes was injured by performance fees. (Dkt. No. 294 at 28.) Plaintiffs 19 subsequently asserted the California Credit Services Act (“Credit Act”) permits them to “recoup 20 the money they paid toward performance fees—even if those fees did not injure Plaintiffs.” (Dkt. 21 No. 341 at 7.) Pending before the Court is GreenSky’s motion for partial summary judgment on 22 the issue of “performance fee recoveries sought by named Plaintiff Heidi Barnes.” (Dkt. No. 338 23 at 6.) Having carefully reviewed the parties’ submissions, and with the benefit of oral argument 24 on September 18, 2025 and supplemental briefing, the Court GRANTS GreenSky’s motion for 25 partial summary judgment. The Credit Act does not permit recovery of amounts paid that did not 26 result in injury and are unrelated to the injury conferring statutory standing to sue. 27 1 BACKGROUND 2 The Court’s January 2, 2025 order contains a detailed summary of the factual and 3 procedural history in this case. (Dkt. No. 279 (sealed); Dkt. No. 294 (unsealed).) Briefly, 4 Greensky partners with contractors (“merchants”) and banks to provide point-of-sale loans to 5 consumers for home-improvement and home-maintenance projects. (Dkt. No. 294 at 1.) 6 GreenSky collects two types of fees. (Id. at 2.) First are “transaction fees,” which the merchant 7 pays GreenSky when a consumer uses a GreenSky Program loan to pay the merchant. (Id.) 8 Second are “performance fees,” which GreenSky receives from bank partners. (Id.) Performance 9 fees are calculated across all loans in the lender’s portfolio at the end of the month:

10 The [performance fee] includes “all amounts billed to the borrowers, fees and finance charges, less the fixed servicing fee, less all credit 11 losses, [and] less the bank margin or the yield that . . . the servicing fee sets forth that is due to the lender.” (Dkt. No. 235-7 at 33.) “[T]o 12 the extent that the result of that calculation is a positive number,” GreenSky is due the remainder as a performance fee. 13 (Id.) 14 Plaintiffs filed a putative class action against GreenSky, alleging the company’s business 15 practices violate California consumer protection statutes. The amended complaint alleges (1) 16 violations of the Credit Act, Cal. Civ. Code §§ 1789.10; (2) violations of California’s Unfair 17 Competition Law (“UCL”), Cal. Bus. & Prof. Code § 17200, including for predicate California 18 Financing Law (“Financing Law”), Cal. Fin. Code § 22000, violations; and (3) unjust enrichment. 19 (Dkt. No. 216.) The amended complaint alleges entities that make or broker consumer loans in 20 California and assist consumers in obtaining extensions of credit are regulated by the Financing 21 Law and the Credit Act, respectively. (Id. ¶¶ 15-18.) Both laws require entities to register with 22 the California Department of Justice or Department of Business Oversight and disclose specified 23 information to consumers. (Id. ¶ 19.) Both laws “also limit the nature and amount of fees that 24 lenders, brokers, and credit services organizations may charge.” (Id. ¶ 20.) The amended 25 complaint alleges GreenSky fails to comply with the Financing Law’s and Credit Act’s 26 requirements. As a result, “Plaintiffs and Class members have suffered injury and damages, 27 including that they paid more in connection with their GreenSky-serviced loans than they 1 otherwise would have.” (Id. ¶ 111.) 2 GreenSky moved for “summary judgment on each of Plaintiffs’ claims,” asserting 3 Plaintiffs “failed to adduce any evidence to show that (a) their GreenSky Program merchants 4 passed through to them any portion of the ‘transaction fee’ the merchants paid GreenSky related to 5 Plaintiffs’ loans, or (ii) they paid any part of an ‘incentive payment’ that Program banks paid to 6 GreenSky pursuant to negotiated contracts between GreenSky and those lenders.”2 (Dkt. No. 254 7 at 7.) Essentially, GreenSky argued Plaintiffs could not prove they were injured by paying 8 transaction fees or performance fees, so “Plaintiffs’ claims relating to such payments [could not] 9 survive summary judgment.” (Id. at 22.) 10 In its Order, the Court observed Plaintiffs’ Credit Act, UCL, and unjust enrichment claims 11 all “require[] proof of injury.” (Dkt. No. 294 at 13.) On this issue, “Plaintiffs presented evidence 12 creating a dispute of fact as to injury resulting from transaction fees, but Plaintiffs [did] not 13 present[] evidence creating a dispute of fact as to performance fees.” (Id.) Regarding transaction 14 fees, Plaintiffs’ theory was that Ms. Barnes, Mr. Ferguson, and every class member paid GreenSky 15 transaction fees because the merchants “passed through a portion of the transaction fee to them . . . 16 in the form of inflated project costs.” (Id.) Plaintiffs contend the imposition of transaction fees 17 violates Credit Act section 1789.13(d)(2) because the fees “are derived from payments made by 18 buyers to GreenSky’s bank partners for costs, fees, finance charges, or principal,” as well as 19 Financing Law section 22305, because—at least as to Mr. Ferguson—GreenSky “charge[d] 20 administrative fees in excess of $50 for loans of $2500 or less, and $75 for loans more than 21 $2500.” (Dkt. No. 216 ¶¶ 109(a), 116(f).)3 As evidence, Plaintiffs filed an expert report 22 “conclud[ing] every class member paid transaction fees in the form of inflated project costs.” 23 (Dkt. No. 294 at 35.) So, Plaintiffs argued, GreenSky’s imposition of the transaction fee via a 24 pass through injured consumers. (Id.; Dkt. No. 235-3 at 29 (class certification motion arguing 25

26 2 “Transaction fees” are also referred to as “merchant fees,” and “performance fees” are also referred to as “incentive payments.” (Dkt. No. 294 at 2.) 27 3 The Court held GreenSky was entitled to summary judgment on Ms. Barnes’s section 22305 1 “[t]he fact that GreenSky’s unlawful transaction fees were passed through to the class, inflating 2 the prices of their projects, constitutes an injury under California law”).) Because Plaintiffs 3 presented evidence creating a dispute of fact, the Court denied GreenSky’s summary judgment 4 motion as to the transaction fee claims. (Dkt. No. 294 at 19.) 5 Regarding performance fees, Plaintiffs argued GreenSky’s collection of performance fees 6 also violated Credit Act § 1789.13(d)(2). (Dkt. No. 294 at 15.) Section 1789.13(d)(2) prohibits a 7 credit services organization from:

8 Charg[ing] or receiv[ing] any money or other valuable consideration for referral of the consumer to a retail seller or other credit grantor 9 who will or may extend credit to the consumer, if . . . The money or consideration is paid by the credit grantor or is derived from the 10 consumer’s payments to the credit grantor for costs, fees, finance charges, or principal. 11 Cal. Civ. Code § 1789.13(d)(2).

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Bluebook (online)
Elizabeth Belyea, et al. v. GreenSky, Inc., et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/elizabeth-belyea-et-al-v-greensky-inc-et-al-cand-2025.