Jennifer Willison v. Nelnet, Inc.

CourtCourt of Appeals for the Sixth Circuit
DecidedMarch 25, 2021
Docket20-3538
StatusUnpublished

This text of Jennifer Willison v. Nelnet, Inc. (Jennifer Willison v. Nelnet, Inc.) 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
Jennifer Willison v. Nelnet, Inc., (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0159n.06

No. 20-3538

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Mar 25, 2021 DEBORAH S. HUNT, Clerk JENNIFER WILLISON, ) ) Plaintiff-Appellant, ) ON APPEAL FROM THE ) UNITED STATES DISTRICT v. ) COURT FOR THE SOUTHERN ) DISTRICT OF OHIO NELNET, INC., ) ) OPINION Defendant-Appellee. ) )

Before: DAUGHTREY, MOORE, and THAPAR, Circuit Judges.

KAREN NELSON MOORE, Circuit Judge. This case reaffirms the trite but still true

aphorism: timing is everything. Plaintiff Jennifer Willison alleges that Defendant Nelnet, a

company that facilitates the repayment of student loans, violated the Fair Debt Collection Practices

Act (“FDCPA”), 15 U.S.C. § 1692 et seq., after it acquired Willison’s student loans for servicing.

The resolution of this case turns on the status of Willison’s loans when Nelnet acquired them.

Because Willison’s loans were not in default at the time Nelnet acquired her loans, Nelnet was not

a debt collector for purposes of the FDCPA, and all of Willison’s claims under the FDCPA must

fail. Thus, we AFFIRM the district court’s grant of summary judgment in favor of Nelnet.

I. BACKGROUND

Some time ago, Willison took out student loans to finance her education. R. 1-1 (Letter to

Nelnet at 1) (Page ID #31). Unfortunately, in 2016, Willison fell behind on her payments, and her

loans went into default. R. 12 (Loan Detail at 2) (Page ID #115). To remove her loans from No. 20-3538, Willison v. Nelnet, Inc.

default status, Willison entered into a “Rehabilitation Agreement” with Performant Recovery, Inc.

R. 1-2 (Rehabilitation Agreement) (Page ID #38). The agreement required Willison to make

monthly payments of no less than five dollars until she received a notification “that [her] loan(s)

ha[d] been sold to a participating rehabilitation lender.” Id. The loans would be removed from

default status once the sale to a rehabilitation lender was completed. Id. Willison made the

required payments. R. 2-2 (Payment History at 1) (Page ID #66). Then on February 15, 2017,

Deutsche Bank, the lender at the time, sold the loans to SunTrust Bank, and the status of the loans

changed from default to being in repayment. R. 12 (Loan Detail at 2) (Page ID #115). That same

day, Nelnet became the new servicer for the loans. Id.

In keeping with its responsibility as servicer for the loans, Nelnet sent Willison a letter

detailing her account balance and repayment schedule. R. 2-3 (Status Change Letter at 1) (Page

1) (Page ID #68). Upon receiving the letter, Willison became concerned about the account

balance; in particular, she believed that Nelnet improperly added $4,000 to $5,000 to the balance

of the loan. R. 1-1 (Letter to Nelnet at 1) (Page ID #31). So, Willison obtained counsel, who sent

a letter to Nelnet inquiring about this issue and requesting that Nelnet send all further

correspondence to counsel. Id. Nelnet sent its response to Willison, instead of to her counsel, and

requested Willison’s permission to release her account information to her attorney, a third party.

R. 1-2 (Nelnet Response Letter) (Page ID #36).

In turn, Willison filed a complaint in federal court against Nelnet, alleging that (1) Nelnet’s

direct communication with Willison after receiving notice that all correspondence should be

directed to her counsel and (2) its misrepresentation of her account balance violated the FDCPA.

Nelnet filed a motion to dismiss, or in the alternative, a motion for summary judgment. Both

2 No. 20-3538, Willison v. Nelnet, Inc.

parties consented to a magistrate judge conducting the proceedings pursuant to 28 U.S.C. § 636(c).

R. 9 (Mag. J. Referral Order) (Page ID #99). The magistrate judge found that both parties relied

on evidence outside of the pleadings and determined that Nelnet’s motion should be treated as a

motion for summary judgment. R. 11 (Order) (Page ID #103). After allowing both parties the

opportunity to submit additional evidence, the magistrate judge granted summary judgment in

favor of Nelnet. Willison v. Nelnet, Inc., No. 2:19-cv-3603, 2020 WL 1914810 (S.D. Ohio Apr.

20, 2020). Willison appealed.

II. DISCUSSION

A. Standard of Review

We review a grant of summary judgment de novo. Mazur v. Young, 507 F.3d 1013, 1016

(6th Cir. 2007). “In deciding a motion for summary judgment, this court views the factual evidence

and draws all reasonable inferences in favor of the non-moving party.” B.F. Goodrich Co. v. U.S.

Filter Corp., 245 F.3d 587, 591–92 (6th Cir. 2001). We will uphold a grant of summary judgment

only when “there is no genuine dispute as to any material fact and the movant is entitled to

judgment as a matter of law.” Fed. R. Civ. P. 56(a). A genuine dispute of material fact exists “if

the evidence is such that a reasonable jury could return a verdict for the nonmoving party.”

Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986).

B. Analysis

Willison argues that the district court erroneously found that Nelnet is not a “debt collector”

for purposes of FDCPA liability. Congress enacted the FDCPA to protect consumers from and to

eliminate “abusive, deceptive, and unfair debt collection practices.” 15 U.S.C. § 1692(a), (b), (e).

For Nelnet to be liable for any alleged violations of the FDCPA, Willison must show that Nelnet

3 No. 20-3538, Willison v. Nelnet, Inc.

is a “debt collector” as defined by the Act. Kistner v. Law Offs. of Michael P. Margelefsky, LLC,

518 F.3d 433, 435–36 (6th Cir. 2008).

Under the FDCPA, a “debt collector” is “any person who uses any instrumentality of

interstate commerce or the mails in any business the principal purpose of which is the collection

of any debts, or who regularly collects or attempts to collect, directly or indirectly, debts owed or

due or asserted to be owed or due another.” 15 U.S.C. § 1692a(6). However, the FDCPA also

provides for several exceptions, one of which is relevant here. If the debt at issue “was not in

default at the time it was obtained,” then a person collecting or attempting to collect such debt does

not qualify as a “debt collector.” Id. at § 1692a(6)(F)(iii). Loan servicers, although they do not

technically own loans, do not fall outside of the FDCPA’s ambit. We have held that “a loan

servicer . . . can . . . become a debt collector, depending on whether the debt was assigned for

servicing before the default or alleged default occurred.” Bridge v. Ocwen Fed. Bank, FSB, 681

F.3d 355, 359 (6th Cir. 2012); Wadlington v.

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Mazur v. Young
507 F.3d 1013 (Sixth Circuit, 2007)
Bridge v. Ocwen Federal Bank, FSB
681 F.3d 355 (Sixth Circuit, 2012)
Henson v. Santander Consumer USA Inc.
582 U.S. 79 (Supreme Court, 2017)
Wadlington v. Credit Acceptance Corp.
76 F.3d 103 (Sixth Circuit, 1996)

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