Favata v. JD Motors

CourtDistrict Court, N.D. New York
DecidedJune 11, 2025
Docket5:23-cv-01549
StatusUnknown

This text of Favata v. JD Motors (Favata v. JD Motors) is published on Counsel Stack Legal Research, covering District Court, N.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Favata v. JD Motors, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK

SCOTT M. FAVATA and KRISTINA S. MULLEN,

Plaintiffs, 5:23-cv-01549 (BKS/TWD)

v.

JD MOTORS OF CNY, LTD., d/b/a JD Motors, and CREDIT ACCEPTANCE CORPORATION,

Defendants.

Appearances: For Plaintiffs: Russell W. Dombrow Dombrow Law Firm 499 South Warren Street, Suite 405 Syracuse, NY 13202

For Defendant Credit Acceptance Corporation: Chester R. Ostrowski McLaughlin & Stern, LLP 260 Madison Avenue New York, NY 10016 Hon. Brenda K. Sannes, Chief United States District Judge: MEMORANDUM-DECISION AND ORDER I. INTRODUCTION Plaintiffs Scott M. Favata and Kristina S. Mullen brought this action against Defendants JD Motors of CNY, Ltd. and Credit Acceptance Corporation, alleging violations of the Truth in Lending Act (“TILA”), 15 U.S.C. § 1601 et seq., the Magnuson-Moss Warranty Act, 15 U.S.C. § 2301, et seq., New York Personal Property Law § 302, and the New York General Business Law § 349, breach of the implied warranty of merchantability and the implied warranty of serviceability, and the “Holder Rule” promulgated by the Federal Trade Commission, as well as claims of negligence, breach of contract, and unjust enrichment. (Dkt. No. 4). Plaintiffs also seek declaratory relief. (Id. ¶¶ 167-172). Defendant JD Motors has not answered the Amended Complaint or otherwise appeared in this action. Presently before the Court is Plaintiffs’ motion to vacate, under Rule 60(b) of the Federal Rules of Civil Procedure, the dismissal of Defendant

Credit Acceptance Corporation (“CAC”). (Dkt. Nos. 36, 24). The motion is fully briefed. (Dkt. Nos. 36-4, 37, 40). Also pending before the Court is Plaintiffs’ motion for default judgment against Defendant JD Motors. (Dkt. No. 31). For the reasons that follow, Plaintiffs’ motion to vacate is denied, and Plaintiffs’ motion for default judgment is denied.

II. BACKGROUND A. Facts1 JD Motors is a Retail Motor Vehicle Dealer licensed by the New York State Department of Motor Vehicles located in Fulton, NY. (Dkt. No. 4, ¶ 16). On December 9, 2022, Plaintiffs were driving through the City of Fulton when they saw JD Motors’ “lot with a sign on it that said the dealership financed ‘everyone.’” (Id. ¶ 22). Mr. Favata “had experienced credit challenges[,]” so Plaintiffs decided to stop at JD Motors’ lot. (Id. ¶ 23). JD Motors showed Plaintiffs a 2011 Ford F-150 available for sale. (Id. ¶¶ 21, 24). JD Motors’ salesperson “represented . . . that JD Motors was selling the F-150 below ‘book value,’ and that the F-150 was a ‘good truck,’ and that the F-150’s frame and structure were ‘solid.’” (Id. ¶ 26). JD Motors did not disclose that “the truck had so much rubberized undercoating on it to conceal the frame and underbody’s true condition, which was thoroughly rusted.” (Id. ¶ 27). JD

1 The facts are taken from the Amended Complaint. (Dkt. No. 4). Because Defendant JD Motors has failed to respond to the Amended Complaint, or otherwise appear in this case, the well-pleaded allegations therein are deemed admitted and assumed to be true for purposes of this Motion. See Greyhound Exhibitgroup, Inc. v. E.L.U.L. Realty Corp., 973 F.2d 155, 158 (2d Cir. 1992). Motors also did not disclose “that the cab corners had body filling and duct tape concealing the damage.” (Id.). Mr. Favata test drove the F-150, but did not “observe the rust and holes in the truck’s body[,]” because JD Motors “concealed those defects with, for example, rubberized undercoating, duct tape, body ‘filler,’ and possibly other materials.” (Id. ¶ 25).

Many of the allegations in the Amended Complaint are made “upon information and belief,” including all of the allegations regarding the documentation of the sale of the truck. (Id. ¶¶ 29-47). It alleges, “upon information and belief,” the following. Plaintiffs each electronically signed a credit application “as a secondary source of income.” (Id. ¶¶ 29, 32). JD Motors never explained to Plaintiffs “what [they were] signing nor provided [them] with a copy of the completed document to review” before asking them to e-sign. (Id. ¶¶ 30, 33). JD Motors also “did not allow” Mr. Favata or Ms. Mullen “to see the computer monitor the document appeared on[,]” or to “control the equipment used to enter” their “personal identifiable information (PII) into the document.” (Id. ¶¶ 31, 34). Plaintiffs also e-signed Credit Report Authorization Forms at JD Motors’ request. (Id. ¶ 35).

The Amended Complaint further alleges “upon information and belief” that JD Motors had Plaintiffs each “e-sign a Retail Instalment (sic) Contract (RIC), to memorialize the transaction’s loan terms[,]” (id. ¶ 38), but “never obtained” Plaintiffs’ “consent to e-sign the RIC,” (id. ¶¶ 41, 45). JD Motors “did not provide a copy of the RIC, without any blank spaces” to the Plaintiffs, “so they could review the RIC before signing[.]” (Id. ¶ 39). The RIC attached to the Amended Complaint lists Truth in Lending Disclosures in bold and has the Plaintiffs’ electronic initials or signature on each page. (Dkt. No. 4-2). The RIC lists JD Motors as the “Creditor-Seller.” (Id. at 2). The RIC states that “[t]he original retail installment contract is assigned to Credit Acceptance Corporation.” (Id.). CAC is “an auto finance lender in the subprime market[,]” which “purchased, acquired, and serviced” Plaintiffs’ auto finance loan from JD Motors. (Dkt. No. 4, ¶¶ 18-19). Plaintiffs allege that CAC provided JD Motors “with the interest rate at which [CAC] would be willing to buy the RIC from” JD Motors. (Id. ¶ 48). The actual interest rate JD Motors

“deceived [Plaintiffs] into agreeing with in the RIC is higher than the interest rate [CAC] set to purchase the RIC[.]” (Id. ¶ 50). JD Motors never disclosed that CAC was purchasing the RIC from JD Motors at a lower rate, or that JD Motors was making a profit on financing the vehicle purchase. (Id. ¶ 52). JD Motors “presented the interest rate it quoted to Mr. Favata and Ms. Mullen to create the impression that [CAC] mandated that interest rate[,]” and Plaintiffs’ entire monthly payment would be going to CAC. (Id. ¶ 53). Plaintiffs “would have negotiated better interest rate terms, shopped for a better interest rate outside of the dealership, or simply backed out of the transaction” if JD Motors had made Plaintiffs aware that the interest rate being offered was “designed to maximize JD Motors [sic] rather than being the lowest interest rate JD Motors was willing to offer[.]” (Id. ¶ 55).

Also, the amended complaint alleges “upon information and belief” that JD Motors did not disclose to Plaintiffs that they were purchasing an extended warranty or service contract during the document signing process, or how much of the money paid for the extended warranty or service contract JD Motors would retain as a commission or profit. (Id. ¶¶ 59-60). Additionally, JD Motors “knew or had reason to know that the $250.00 fees” Plaintiffs paid for processing the “Certificate of Title, License and Registration” exceeded the estimated fees of $179.00, but never disclosed that fact to Plaintiffs nor refunded the overcharge. (Id. ¶¶ 61-66). These items were listed on the RIC. (Id. ¶¶ 56-58). The RIC also contains a section titled “Arbitration Clause” which stated that, if Plaintiffs did not want the Clause to apply, they could reject it by taking certain actions. (Id. ¶¶ 68-69). The RIC contains Plaintiffs’ initials inside a box with “Arbitration” in bold, which notes that there is an arbitration clause and Plaintiffs’ initials on the page describing the arbitration clause.

(Dkt. No. 4-2, at 1, 5).

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