HERNANDEZ v. NEWREZ LLC

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 8, 2024
Docket2:23-cv-03569
StatusUnknown

This text of HERNANDEZ v. NEWREZ LLC (HERNANDEZ v. NEWREZ LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HERNANDEZ v. NEWREZ LLC, (E.D. Pa. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

MISTY HERNANDEZ, f/k/a CIVIL ACTION MISTY WHITE, Plaintiff,

v. NO. 23-3569 NEWREZ, LLC, d/b/a SHELLPOINT MORTGAGE SERVICING, Defendant.

MEMORANDUM OPINION Plaintiff Misty Hernandez brings individual and putative class claims alleging Defendant Shellpoint Mortgage Servicing violated the Real Estate Settlement Procedures Act, 12 U.S.C. §§ 2601 (RESPA), and the Fair Credit Reporting Act, 15 U.S.C. §§ 1681 (FCRA). Shellpoint has moved to strike Plaintiff’s class allegations pursuant to Fed. R. Civ. P. 12(f), 23(c)(1)(A), and 23(d)(1)(D). For the reasons that follow, Shellpoint’s Motion will be denied. I. BACKGROUND Hernandez alleges that Shellpoint, a loan servicer, engaged in a pattern and practice of failing to properly process her and others’ home-mortgage payments. She claims that these failures led to “negligent or improper credit reporting” and the assessment of “prohibited or improper fees.” RESPA was enacted to ensure “that consumers throughout the Nation are provided with greater and more timely information on the nature and costs of the settlement process and are protected from unnecessarily high settlement charges caused by certain abusive practices that have developed in some areas of the country.” 12 U.S.C. § 2601. Among other things, RESPA requires loan servicers to respond to certain consumer requests for information or correction: Qualified Written Requests (QWR), Requests for Information (RFI), and Notices of Error (NOE). In 2010, The Consumer Financial Protection Bureau issued “Regulation X,” which clarified and expanded the category of requests to which mortgage servicers must respond. FCRA requires any company that furnishes consumer credit information to credit-reporting

agencies to take certain steps when a consumer believes the company has furnished inaccurate information. Here, Hernandez alleges that Shellpoint violated both RESPA and FCRA with respect to her and a class of similarly situated borrowers. II. LEGAL STANDARD Rule 12(f) governs motions to strike. It provides that the Court, “on its own” or “on motion made by a party,” may strike from a pleading “an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter.” And under Rule 23(d)(1)(D), the Court may “require that the pleadings be amended to eliminate allegations about representation of absent persons and that the action proceed accordingly.”

III. DISCUSSION A. High Bar to Strike Class Allegations As an initial matter: The parties have not completed class discovery and Hernandez has not yet filed a motion for class certification. Shellpoint argues that it is nonetheless appropriate to strike Hernandez’ class allegations at this stage. For support it cites Donelson v. Ameriprise Financial Services, Inc., in which the Eighth Circuit held that class allegations may be stricken at the pleading stage if the allegations are “unsupportable” and “bring impertinent material into the pleading,” and permitting them to remain “would prejudice the defendant by requiring the mounting of a defense against claims that ultimately cannot be sustained.” 999 F.3d 1080, 1092 (8th Cir. 2021) (quotations omitted). Motions to strike of all sorts are “disfavored” and “usually denied unless the allegations have no possible relation to the controversy and may cause prejudice to one of the parties, or if

the allegations confuse the issues.” Woodard v. FedEx Freight E., Inc., 250 F.R.D. 178, 181-82 (M.D. Pa. 2008). District courts are “generally reluctant” to strike class allegations before discovery or certification unless “where the complaint and any affidavits clearly demonstrate that the plaintiff cannot meet the requirements for a class action.” Id. at 182. In Woodard, for instance, the court granted FedEx’s motion to strike Woodard’s class allegations because it found it lacked jurisdiction over them. Because the bar for granting a motion to strike class allegations before class certification is so high, “district courts within the Third Circuit typically conclude that motions to strike class action allegations filed before plaintiffs move for class certification are premature.” Goode v. LexisNexis Risk & Info. Analytics Grp., Inc., 284 F.R.D. 238, 244 (E.D. Pa. 2012). To make a

final class-certification decision under Rule 23, “a district court must conduct a rigorous analysis, [in which it] may delve beyond the pleadings to determine whether the requirements for class certification are satisfied,” and that “rigorous analysis” typically requires “[d]iscovery and full briefing on the merits of class certification.” Id. at 244-45 (quotations omitted). As a result, “[i]t is only when no amount of discovery or time will allow for plaintiffs to resolve deficiencies in class definitions under Rule 23, that a motion to strike class allegations should be granted.” Zarichny v. Complete Payment Recovery Servs., Inc., 80 F. Supp.3d 610, 615 (E.D. Pa. 2015). See also Richardson v. Bledsoe, 829 F.3d 273, 288-89 (3d Cir. 2016) (“a court should typically await the development of a factual record before determining whether the case should move forward on a representative basis.”).1 Shellpoint argues that Hernandez’ class allegations should be stricken, even this early, because they are impermissible as pleaded and no amendment could save them. It raises two

contentions: first, that Hernandez’ classes as defined are improper fail-safe classes; second, that Hernandez’ classes require detailed individualized inquiries to determine membership and therefore cannot satisfy Rule 23(b)(3)’s requirement that “questions of law or fact common to class members predominate over any questions affecting only individual members.” Both contentions will be assessed below against the high standard a motion to strike must meet. B. Failsafe Classes Shellpoint first argues that Hernandez’ class allegations should be stricken on the grounds that they are impermissible fail-safe classes. A fail-safe class is “one that is defined so that whether a person qualifies as a member depends on whether the person has a valid claim.” Byrd v. Aaron’s Inc., 784 F.3d 154, 167 (3d Cir. 2015), as amended (Apr. 28, 2015). The Third Circuit

“ha[s] never expressly held that fail-safe classes are impermissible,” though “other circuits, such

1 There are good policy reasons to maintain trigger discipline with regard to class allegations. “The policy at the very core of the class action mechanism is to overcome the problem that small recoveries do not provide the incentive for any individual to bring a solo action prosecuting his or her rights. A class action solves this problem by aggregating the relatively paltry potential recoveries into something worth someone’s (usually an attorney’s) labor.” Amchem Prod., Inc. v. Windsor, 521 U.S. 591, 617 (1997). And

The most compelling [use of a class action] occurs when someone inflicts a small harm on each member of a large group of people.

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Bluebook (online)
HERNANDEZ v. NEWREZ LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-v-newrez-llc-paed-2024.