Gallick v. Educational Credit Mgt. Co.

2023 Ohio 278, 207 N.E.3d 868
CourtOhio Court of Appeals
DecidedJanuary 31, 2023
Docket21AP0054
StatusPublished

This text of 2023 Ohio 278 (Gallick v. Educational Credit Mgt. Co.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gallick v. Educational Credit Mgt. Co., 2023 Ohio 278, 207 N.E.3d 868 (Ohio Ct. App. 2023).

Opinion

[Cite as Gallick v. Educational Credit Mgt. Co., 2023-Ohio-278.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF WAYNE )

DONALD GALLICK C.A. No. 21AP0054

Appellan

v. APPEAL FROM JUDGMENT ENTERED IN THE EDUCATIONAL CREDIT COURT OF COMMON PLEAS MANAGEMENT CO., et al. COUNTY OF WAYNE, OHIO CASE No. 2019-CVC-H-00341 Appellees

DECISION AND JOURNAL ENTRY

Dated: January 31, 2023

HENSAL, Judge.

{¶1} Donald Gallick appeals a journal entry of the Wayne County Court of Common

Pleas that granted summary judgment to Nelnet, Inc., Educational Credit Management Corp.

(“ECMC”), and American Student Assistance (“ASA”) on his claims. For the following reasons,

this Court affirms.

I.

{¶2} Mr. Gallick consolidated his student loans into two loans in 2002, and Deutsche

Bank later became the holder of the loans. In December 2017, Nelnet became the servicer of the

loans for Deutsche Bank. At the time, the combined balance of the loans was around $54,000.00.

{¶3} According to Mr. Gallick, he had received correspondence from several companies

throughout 2017 about his loans and wanted to make sure that Nelnet was not attempting to defraud

him when it notified him that it was the servicer of his loans. He wrote Nelnet seeking verification

of its status, but Nelnet did not respond in writing. Instead, it attempted to discuss Mr. Gallick’s 2

loans over the telephone. Mr. Gallick preferred written communication, however, because of the

difficulty in creating a record of telephone conversations.

{¶4} Mr. Gallick alleges that, on April 27, 2018, he sent a letter and a check in the

amount of $900.00 to Nelnet. In the letter, Mr. Gallick wrote that, unless he received written

communication from Nelnet within 30 days, he would assume that the check fully satisfied his

alleged debt. According to Nelnet’s records, it did not receive the letter and check until May 31,

2018. It applied the $900.00 to Mr. Gallick’s account and sent him a letter on June 6, 2018,

indicating that the amount was insufficient to pay off his loans. Mr. Gallick replied with a letter

stating that he considered his debt satisfied under the doctrine of accord and satisfaction and made

no further payments.

{¶5} In August 2019, Nelnet declared Mr. Gallick’s loans in default. As guarantor of

the loans, ASA made a payment to Deutsche Bank and the note was assigned to it. ECMC, a

guarantor servicer for ASA, began contacting Mr. Gallick in writing and by telephone about his

defaulted loans. Mr. Gallick subsequently filed a complaint against Nelnet and ECMC, seeking a

declaratory judgment that his student loans had been satisfied under the doctrine of accord and

satisfaction. He also sued them for violations of the Ohio Consumer Sales Practices Act (“CSPA”),

harassment, and fraud. The trial court required Mr. Gallick to add Deutsche Bank and ASA to the

action because a declaratory judgment regarding the status of the loans could affect their interests.

The trial court granted a judgment of default against Deutsche Bank after it did not file an answer.

Nelnet, ECMC, and ASA moved for summary judgment. The trial court granted their motions as

to all the claims over Mr. Gallick’s opposition. Mr. Gallick has appealed, assigning four errors.

II.

ASSIGNMENT OF ERROR I 3

THE TRIAL COURT ERRED BY GRANTING SUMMARY JUDGMENT ON THE CLAIMS FOR DECLARATORY RELIEF BASED ON THE DOCTRINE OF ACCORD AND SATISFACTION.

{¶6} In his first assignment of error, Mr. Gallick argues that the trial court should not

have granted summary judgment to Nelnet, ECMC, and ASA on his accord and satisfaction claim.

Under Civil Rule 56(C), summary judgment is appropriate if:

[n]o genuine issue as to any material fact remains to be litigated; (2) the moving party is entitled to judgment as a matter of law; and (3) it appears from the evidence that reasonable minds can come to but one conclusion, and viewing such evidence most strongly in favor of the party against whom the motion for summary judgment is made, that conclusion is adverse to that party.

Temple v. Wean United, Inc., 50 Ohio St.2d 317, 327 (1977). To succeed on a motion for summary

judgment, the party moving for summary judgment must first be able to point to evidentiary

materials that demonstrate there is no genuine issue as to any material fact, and that it is entitled

to judgment as a matter of law. Dresher v. Burt, 75 Ohio St.3d 280, 292 (1996). If the movant

satisfies this burden, the nonmoving party “must set forth specific facts showing that there is a

genuine issue for trial.” Id. at 293, quoting Civ.R. 56(E). This Court reviews an award of summary

judgment de novo. Grafton v. Ohio Edison Co., 77 Ohio St.3d 102, 105 (1996).

{¶7} In count one of his amended complaint, Mr. Gallick sought a declaration that his

student loans had been fully satisfied by the doctrine of accord and satisfaction, as codified by

Ohio Revised Code Section 1303.40. The trial court granted summary judgment to the defendants

on count one for different reasons. It granted judgment to Nelnet because it determined that Mr.

Gallick had failed to demonstrate that there was a bona fide dispute about the debt he owed. It

granted judgment to ECMC and ASA because it determined that Mr. Gallick’s claim was

preempted by federal law. Mr. Gallick has challenged both conclusions. 4

{¶8} Regarding Nelnet, with certain exceptions, Section 1303.40(A) provides that, “[i]f

a person against whom a claim is asserted proves that that person in good faith tendered an

instrument to the claimant as full satisfaction of the claim, that the amount of the claim was

unliquidated or subject to a bona fide dispute, and that the claimant obtained payment of the

instrument,” “the claim is discharged if the person against whom the claim is asserted proves that

the instrument or an accompanying written communication contained a conspicuous statement to

the effect that the instrument was tendered as full satisfaction of the claim.” “‘Good faith’ * * *

means honesty in fact and the observance of reasonable commercial standards of fair dealing.”

R.C. 1301.201(B)(20).

{¶9} Mr. Gallick testified at his deposition that, throughout 2017, there were multiple

companies that asked him to pay them money for his student loans. In December 2017, a company

called Conduent sent him a document with his account information that indicated that the principal

balance outstanding on his loans was $53,789.91. Mr. Gallick did not question the accuracy of the

information and did not believe that he owed only $900 on his loans at that time. Two weeks after

receiving the statement from Conduent, he received a letter from Nelnet explaining that it was

taking over as the servicer of his loans. This caused Mr. Gallick to begin looking into the status

of his student loans. Mr. Gallick testified that he did not calculate what the actual principle of his

loans was, he only thought that, because he had been paying the loans off for close to 30 years,

they might already have been paid off for a long time. He acknowledged that, because of changes

in his employment over the years, there had been periods where his payments on the loans were

deferred. He also acknowledged that when he consolidated his loans in 2002, the combined

amount of the loans was $91,817. 5

{¶10} Upon review of the record, we conclude that the trial court did not err when it

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cliff v. Payco General American Credits, Inc.
363 F.3d 1113 (Eleventh Circuit, 2004)
English v. General Electric Co.
496 U.S. 72 (Supreme Court, 1990)
Tipton v. Secretary of Education of the United States
768 F. Supp. 540 (S.D. West Virginia, 1991)
Rude v. NUCO Edn. Corp.
2011 Ohio 6789 (Ohio Court of Appeals, 2011)
Menorah Park Ctr. for Senior Living v. Rolston (Slip Opinion)
2020 Ohio 6658 (Ohio Supreme Court, 2020)
Temple v. Wean United, Inc.
364 N.E.2d 267 (Ohio Supreme Court, 1977)
Gaines v. Preterm-Cleveland, Inc.
514 N.E.2d 709 (Ohio Supreme Court, 1987)
Dresher v. Burt
662 N.E.2d 264 (Ohio Supreme Court, 1996)
Groob v. KeyBank
843 N.E.2d 1170 (Ohio Supreme Court, 2006)
Grafton v. Ohio Edison Co.
1996 Ohio 336 (Ohio Supreme Court, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 278, 207 N.E.3d 868, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gallick-v-educational-credit-mgt-co-ohioctapp-2023.