Holm v. Acima Credit Digital, LLC

District Court, S.D. California·Decided March 27, 2025·No. 3:24-cv-02345·Unknown

Opinion

GABERICK HOLM, individually, and on Case No.: 3:24-CV-02345-GPC-DTF behalf of all others similarly situated, ORDER GRANTING PLAINTIFF’S Plaintiff, MOTION FOR LEAVE TO FILE AN v. AMENDED COMPLAINT

ACIMA CREDIT DIGITAL, LLC (f/k/a [Dkt. No. 24.] ACIMA CREDIT, LLC d/b/a ACIMA Defendant. Before the Court is Plaintiff’s motion for leave to file an amended complaint. (Dkt. No. 24.) Defendant filed an opposition, (Dkt. No. 28), and Plaintiff filed a reply. (Dkt. No. 30.) Based on the reasoning below, the Court GRANTS Plaintiff’s motion for leave to file an amended complaint. Background On October 23, 2024, Plaintiff Gaberick Holm (“Plaintiff”) filed a putative class action complaint in San Diego Superior Court against Defendant Acima Credit Digital, LLC (“Defendant”) alleging violations of the Military Lending Act, 10 U.S.C. § 987, et. seq., (“MLA”) and the Truth in Lending Act, 15 U.S.C. § 1638, for Defendant’s alleged lending practices. As to the MLA, Plaintiff claims that Defendant’s loans (1) charge interest above the 36% statutory Military Annual Percentage Rate (“MAPR”) cap; (2) fail to provide any required MLA Disclosures; (3) include a Class Action Ban and Waiver of Jury Trial; and (4) include a mandatory binding arbitration clause. (Dkt. No. 1-2, Compl. ¶ 54.) On December 16, 2024, Defendant removed the action to this Court on federal question jurisdictional grounds.1 (Dkt. No. 1.) In this motion, Plaintiff seeks to amend his complaint to: (1) allege “additional facts bearing on the question of whether Defendant’s purported leases were, in fact, consumer credit agreements covered by the MLA”; and (2) clarify the “contours of the putative classes.” (Dkt. No. 24-1 at 2.2) According to Plaintiff, these amendments are necessary to “the Court’s analysis of the agreement at issue and whether the MLA applies, in which case the arbitration provision and class waiver [at issue] are void.” Id. Defendant opposes arguing that that proposed amendments “are futile and . . . unfairly prejudice Defendant . . . .” (Dkt. No. 28.) On March 6, 2025, Plaintiff filed a reply. (Dkt. No. 30.) Discussion Under Federal Rule of Civil Procedure (“Rule”) 15, courts “should freely give leave [to amend] when justice so requires.” Fed. R. Civ. P. 15(a)(2); see also Foman v. Davis, 371 U.S. 178, 182 (1962) (“Rule 15(a) declares that leave to amend ‘shall be freely given when justice so requires’; this mandate is to be heeded.”); DCD Programs, Ltd. v. Leighton, 833 F.2d 183, 186 (9th Cir. 1987) (quoting United States v. Webb, 655 F.2d 977, 979 (9th 1 On January 7, 2025, Defendant filed a motion to dismiss class claims and stay individual claims in favor of arbitration. (Dkt. No. 17.) The parties agreed to pause briefing on the motion to dismiss until the Court rules on Plaintiff’s motion for leave to file an amended complaint. (Dkt. Nos. 25, 27.) 2 Page numbers are based on the CM/ECF pagination. Cir. 1981)) (“[R]ule 15’s policy of favoring amendments to pleadings should be applied with ‘extreme liberality.’”). Granting leave to amend rests in the sound discretion of the trial court. Int’l Ass’n of Machinists & Aerospace Workers v. Republic Airlines, 761 F.2d 1386, 1390 (9th Cir. 1985). “Five factors are taken into account to assess the propriety of a motion for leave to amend: bad faith, undue delay, prejudice to the opposing party, futility of amendment, and whether the plaintiff has previously amended the complaint.”3 Johnson v. Buckley, 356 F.3d 1067, 1077 (9th Cir. 2004); see also Foman, 371 U.S. at 182 (Foman factors). These factors do not carry equal weight; the possibility of delay alone, for instance, cannot justify denial of leave to amend, but when combined with a showing of prejudice, bad faith, or futility of amendment, leave to amend will likely be denied. DCD Programs, Ltd., 833 F.2d at 186; Bowles v. Reade, 198 F.3d 752, 757-58 (9th Cir. 1999). The single most important factor is whether prejudice would result to the non-movant as a consequence of the amendment. Eminence Cap., LLC v. Aspeon, Inc., 316 F.3d 1048, 1052 (9th Cir. 2003); William Inglis & Sons Baking Co. v. ITT Continental Baking Co., Inc., 668 F.2d 1014, 1053 n.68 (9th Cir. 1981). “Absent prejudice, or a strong showing of any of the remaining . . . factors, there exists a presumption under Rule 15(a) in favor of granting leave to amend.” Eminence Cap. LLC, 316 F.3d at 1052 (emphasis in original). The burden of demonstrating prejudice falls on the party opposing leave to amend. DCD Programs, Ltd., 833 F.2d at 187. When determining whether to grant leave to amend, courts “must remain guided by ‘the underlying purpose of Rule 15 . . . to facilitate decision on the merits, rather than on the pleadings or technicalities.’” Lopez v. Smith, 203 F.3d 1122, 1127 (9th Cir. 2000) (en banc) (quoting Noll v. Carlson, 809 F.2d 1446 (9th Cir. 1987)).

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