Lynn Strange, individually and on behalf of all others similarly situated v. Capital One, N.A.

District Court, D. Maryland·Decided July 20, 2026·No. 8:25-cv-02711·Unknown

Opinion

□ UNITED STATES DISTRICT COURT ’ DISTRICT OF MARYLAND |

LYNN STRANGE, individually and on behalf of all others □ similarly situated, :

Plaintiff, □

vo ‘Civil Action No. 25-2711-TDC ©

CAPITAL ONE, N.A., :

Defendant. .

_ MEMORANDUM OPINION - Plaintiff Lynn Strange has filed this putative class action against Defendant Capital One, National Association (“Capital One”) in which she alleges that Capital One knowingly collected credit card interest from class members at a rate exceeding the maximum permitted by Virginia law and ‘thereby violated’the National Bank Act, 12 U.S.C. §§ 85-86. Capital One has filed Motion to Dismiss the Amended Complaint, which is fully briefed. The Court held a hearing on the Motion on June 25, 2026. For the reasons set forth below, the Motion willbe GRANTED. oe _ BACKGROUND L Statutory Framework ~ ~The National Bank Act govers the interest rates that national banks such as Capital One are permitted to charge. Specifically, the statute provides that: | Any [national banking] association may take, receive, reserve, and charge on any loan or discount made, or upon any notes, bills of exchange, or other evidences of _ debt, interest at the rate allowed by the laws of the State, Territory, or District where . the bank is located, or at a rate of 1 per centum in excess of the discount rate on ninety-day commercial paper in effect at the Federal reserve bank in the Federal reserve district where the bank is located, whichever may be the greater, and no more, . 12US.C.§85.

The National Bank Act prohibits the “taking, receiving, reserving, or charging a rateof interest greater than is allowed by [12 U.S.C. § 85], when knowingly done.” Id. § 86. If a bank □ has charged interest in violation of this. limitation, it must “forfeit[] “the entire interest which ‘the note, bill, or other evidence of debt carries with it, or which has been agreed to be paid thereon.” Id Under such circumstances, “the person by whom it has been paid, or his legal representatives, may recover back, in an action in the nature of an action of debt, twice the amount of the interest

thus paid from the association taking or receiving the same.” Jd. ‘The statute of limitations for

_ such claims is two years, See id. □□ Because Capital One is based in Virginia, the parties agree that it may charge interest up to the maximum rate permitted by Virginia law. Under Virginia law, the default “legal rate of interest shall be an annual rate of six percent,” which is “implied when there is an obligation to ‘pay interest and no express contract to pay interest at a specified rate.” Va. Code Ann. § 6.2-301 (LexisNexis 202 1). Virginia law further sets the maximum contractual interest rate on loans at 12 percent, subject to certain exceptions. Id. § 62-303, One such exception is for open-end credit plans, in relation to which Virginia law provides that “[nJotwithstanding any statutory or case law, - any bank or savings institution may impose finance charges and other charges and fees at □□□□ - rates and in such amounts and manner as may be agreed by the borrower under an open-end credit plan.” Id § 6.2-313(A). An “open-end credit plan” is “consumer credit extended by a creditor . . under a plan in which: (i) the creditor reasonably contemplates repeated transactions: (ii) the

. creditor may impose a finance charge from time to time on an outstanding unpaid balance; and (iii) the amount of credit that may be extended to the consumer during the term of the plan, up to any limit set by the creditor, is generally made available to the extent that any outstanding balance |

- repaid.” Id. § 6.2-300. Thus, under the ‘National Bank Act and Virginia law, Capital One may charge interest on credit card debt.at any rate if it has an agreement with the cardholder to do so. ° .

_ IL. Capital One Credit Card Agreement .

Defendant Capital One is a national bank based in Virginia that issues credit cards to its .customers. ‘Plaintiff Lynn Strange is a resident of Bowie, Maryland. In or about February 2024, Strange accepted and began using a Capital One credit card in Maryland. □

□□ relation to the provision of the credit card, Capital One provided Strange with a form document entitled “Capital One Customer Agreement” (“the Credit Card Agreement” or “the Agreement”) that stated that the Agreement, “including any changes to it,”.contained “the terms of your agreement with Capital One.” Credit Card Agreement at 1, Kurkowski Decl. A, ECF -

No. 27-3. The Agreement also stated that Strange’s account with Capital One would be governed by the Agreement; credit card statements, privacy notices, materials and disclosures provided upon ‘ - } . - the opening of her account, all other materials and disclosures relating to her account, and □□□□□ future changes” made by Capital One to the Agreement and the other documents. Id. The Credit ‘Card Agreement stated that Capital One would charge interest “as disclosed on your Statement and other Truth-in-Lending Disclosures,” and that Capital One “may increase” the interest charges “as described in, the Changés to Your Agreement section or in your Truth-in- Lending Disclosures.” Jd. at 3. The “Changes to Your Agreement” section provided that: - □□

At any time, we may add, delete or change any term of this Agreement, unless the . law prohibits us from doing so. We will give you notice of any changes as required by law. We may notify you of changes on your Statement or in a separate notice. - - Our notice will tell you when and how the changes will take effect. The notice will □□ - describe any rights you have in connection with the changes. Your variable □ [Annual Percentage Rates (“APRs”)] (if applicable) can go up or down as the index for the rate goes up.or down. If we increase your APRs for any other reason, or if □□ we change your Fees or other terms of your Account, we will notify you as required by law.

Id. at 5, The Agreement specified that the references to “Truth-in-Lending Disclosures” relate to

_ the “disclosures that‘the federal Truth in Lending Act and Regulation Z require” for credit card accounts, including disclosures in relation to “change in terms notices.” Id. at 6. With the approval of her credit card application, Strange received from Capital One a letter with attachments (“the Disclosure Notice”y stating that her APR was 30.74 percent, and that □□ would “vary with the market based on-the Prime Rate.” Disclosure Notice at 3, Kurkowski Decl.. Ex. B, ECF No. 27-4. Although the Credit Card Agreement did not state expressly how or when |

it would become effective, it stated through the Disclosure Notice that Strange was “not obligated

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Lynn Strange, individually and on behalf of all others similarly situated v. Capital One, N.A., (D. Md. 2026).

Lynn Strange, individually and on behalf of all others similarly situated v. Capital One, N.A. (Lynn Strange, individually and on behalf of all others similarly situated v. Capital One, N.A.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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