In Re Terry Patrick Ward, Debtor, Manufacturer's Hanover Trust Company v. Terry Patrick Ward

857 F.2d 1082, 1988 U.S. App. LEXIS 12662, 18 Bankr. Ct. Dec. (CRR) 583, 1988 WL 94692
CourtCourt of Appeals for the Sixth Circuit
DecidedSeptember 16, 1988
Docket87-3525
StatusPublished
Cited by162 cases

This text of 857 F.2d 1082 (In Re Terry Patrick Ward, Debtor, Manufacturer's Hanover Trust Company v. Terry Patrick Ward) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Terry Patrick Ward, Debtor, Manufacturer's Hanover Trust Company v. Terry Patrick Ward, 857 F.2d 1082, 1988 U.S. App. LEXIS 12662, 18 Bankr. Ct. Dec. (CRR) 583, 1988 WL 94692 (6th Cir. 1988).

Opinions

KRUPANSKY, Circuit Judge.

The claim at bar arises from the Chapter 7 bankruptcy proceeding of the defendant-appellee Terry Patrick Ward (Ward). Plaintiff-Appellant Manufacturers Hanover Trust Company (MHT) seeks to except from discharge indebtedness incurred by Ward as a result of his use of a Mastercard which it purportedly issued as a result of false representations made by Ward in his application for the credit card. The bankruptcy court concluded and the district court agreed that MHT’s debt was dis-chargeable. MHT timely appealed.

Ward received the credit card in question upon completion of an application circulated by MHT as part of a nationwide direct mail solicitation sponsored by MHT to enroll new members in its retail consumer credit business. Ward received his credit card from MHT in May of 1985 with a preapproved credit limit of $2,000. During a 23-day period beginning on May 13,1985, and ending on June 5, 1985, he charged $2,200 to this account. The charges included two cash advances of $900 each. MHT admitted that it requested no financial statement from Ward, nor did it conduct a credit check of his financial responsibility, which would have disclosed indebtedness on at least twelve other credit accounts together with an embezzlement conviction ordering a restitution of $250,000. MHT’s [1083]*1083principal witness, Louise Cordeira, assistant manager in charge of retail credit cards, testified that MHT generally requested a credit bureau report which, if received, would have reflected many of Ward’s other liabilities. However, MHT introduced no evidence to support a request for or the receipt of a report concerning Ward.

After Ward filed his Chapter 7 petition, MHT instituted this proceeding seeking to declare his indebtedness to it as non-dis-chargeable under Bankruptcy Code Section 523(a)(2)(A) because the money was obtained by “false representation or actual fraud”.1 To support its position, MHT argued that Ward fraudulently misrepresented that he was financially responsible and would satisfy any and all charges that he incurred against MHT’s extended credit. Appellee responded that the debt was dis-chargeable because MHT had assumed the risk of nonpayment of Ward’s charges against its credit card since it had failed to minimally investigate Ward’s financial responsibility.

To except a debt from discharge under § 523(a)(2)(A), a creditor must prove the following elements set forth in In re Phillips, 804 F.2d 930, 932 (6th Cir.1986):

[T]he creditor must prove that the debtor obtained money through a material misrepresentation that at the time the debt- or knew was false or made with gross recklessness as to its truth. The creditor must also prove the debtor’s intent to deceive. Moreover, the creditor must prove that it reasonably relied on the false representation and that its reliance was the proximate cause of loss. In re Kimzey, 761 F.2d 421, 423 (7th Cir.1985); In re Hagedorn, 25 B.R. 666, 668 (Bankr. S.D.Ohio 1982); 3 Collier on Bankruptcy ¶ 523.08[4] (15th ed. 1985).

In the instant case, it was undisputed that Ward at least impliedly misrepresented his financial capability upon the application circulated by MHT and that he did so intending to deceive MHT. The lower court concluded, however, that the creditor did not “reasonably” rely on Ward’s'false representations because it failed to verify Ward’s credit or to investigate the veracity of his representations. MHT, as the party seeking an exception from discharge in bankruptcy, had the burden to prove reliance by clear and convincing evidence. Phillips, 804 F.2d at 932; Parkey, 790 F.2d at 491. Exceptions to dischargeability are to be construed strictly. Gleason v. Thaw, 236 U.S. 558, 562, 35 S.Ct. 287, 289, 59 L.Ed. 717 (1915); In re Hunter, 780 F.2d 1577, 1579 (11th Cir.1986). In this context, the bankruptcy court’s finding of fact is subject to a clearly erroneous standard of review by this court. Phillips, 804 F.2d at 932; Knoxville Teachers Credit Union v. Parkey, 790 F.2d 490 (6th Cir.1986); In re Martin, 761 F.2d 1163, 1165 (6th Cir.1985).

The bankruptcy court decided in pertinent part that:

The fact is that this company, Manufacturers Hanover, one of the largest banks in the United States, issued two thousand dollars in preapproved credit to a person who was not only hopelessly insolvent, but who had recently been convicted of an embezzlement offense.
While the testimony of the bank officer, the assistant manager in charge of retail credit cards indicated that a credit check must have been made, indeed, the contrary must be true. A credit check could never have been made, because if it [1084]*1084had been made credit would not have been issued. If, in fact, the credit check was made, someone didn’t heed it. ... So as far as I’m concerned, there could not have been [a] credit check.

In disposing of the controversy before it, the court apparently assigned Cordeira’s testimony little, if any, credibility in light of her vague and inconclusive recollections concerning MHT's efforts to obtain a credit bureau report or otherwise investigate Ward’s financial responsibility. In short, MHT failed to meet its burden of introducing clear and convincing evidence that it conducted even the most superficial credit investigation. Accordingly, the trial court’s factual determinations were not clearly erroneous.

Given the correctness of the district court’s factual findings, MHT’s reliance on Ward’s misrepresentation was unreasonable as a matter of law. “Congress was [when passing § 523] ... concerned that creditors use, when feasible, ‘other sources of information, such as credit bureau reports, to verify the accuracy of the [debt- or’s] list of debts.’ ” In re Martin, 761 F.2d at 1166. See also H.R.REP. No. 595, 95th Cong., 1st Sess. 130 (1977), reprinted in 1978 U.S.CODE CONG. & ADMIN. NEWS 5787, 5963, 6091. In cases where “minimal investigation and verification almost certainly would have uncovered the falsity of the representations,” a bank’s debt must be discharged if no such investigation had been performed. In re Mullet, 817 F.2d 677, 680 (10th Cir.1987). “Misplaced trust” is insufficient for nondis-chargeability. A lender must investigate creditworthiness and ferret out ordinary credit information. In re Hunter, 780 F.2d 1577, 1580 (11th Cir.1986). Cf. In re Hansford, 822 F.2d 902, 904 (9th Cir.1987) (assuming that a creditor bears a duty to investigate and verify a debtor’s financial statement) (citing Kentile Floors, Inc. v. Winham, 440 F.2d 1128, 1131-32 (9th Cir.1971)).

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

Related

Gbaz, Inc. v. Conte
N.D. Ohio, 2022
Harper v. Mosley
W.D. Kentucky, 2021
Ballinger v. Smith
W.D. Kentucky, 2020
Flagstar Bank, FSB v. Stricker (In Re Stricker)
414 B.R. 175 (W.D. Michigan, 2009)
Rebekah v. Crownover (In Re Crownover)
417 B.R. 45 (E.D. Tennessee, 2009)
Faruqi v. Anjum (In Re Anjum)
402 B.R. 767 (W.D. Kentucky, 2009)
Willens v. Bones (In Re Bones)
395 B.R. 407 (E.D. Michigan, 2008)
Capital One Auto Finance v. Viva (In Re Viva)
414 B.R. 301 (E.D. Tennessee, 2008)
Digital Commerce, Ltd. v. Sullivan (In Re Sullivan)
305 B.R. 809 (W.D. Michigan, 2004)
Izzo v. United States (In Re Izzo)
287 B.R. 158 (E.D. Michigan, 2002)
Corradini v. Corradini (In Re Corradini)
276 B.R. 571 (W.D. Michigan, 2002)
Bank of America v. Jarczyk
268 B.R. 17 (W.D. New York, 2001)
Insouth Bank v. Michael (In Re Michael)
265 B.R. 593 (W.D. Tennessee, 2001)
At&T Universal Card Services v. Mercer
246 F.3d 391 (Fifth Circuit, 2001)
Metcalfe v. Waters (In Re Waters)
239 B.R. 893 (W.D. Tennessee, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
857 F.2d 1082, 1988 U.S. App. LEXIS 12662, 18 Bankr. Ct. Dec. (CRR) 583, 1988 WL 94692, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-terry-patrick-ward-debtor-manufacturers-hanover-trust-company-v-ca6-1988.