Merchants Credit Corporation, V. Litigation Practice Group P.c.

CourtCourt of Appeals of Washington
DecidedDecember 30, 2024
Docket84104-1
StatusUnpublished

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Merchants Credit Corporation, V. Litigation Practice Group P.c., (Wash. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DAVID TRAHAN, a Washington resident, DIVISION ONE

Plaintiff, No. 84104-1-I

v. UNPUBLISHED OPINION

MERCHANTS CREDIT CORPORATION a/k/a MERCHANTS CREDIT ASSOCIATION, a Washington corporation and licensed collection agency,

Defendant. MERCHANTS CREDIT CORPORATION a/k/a MERCHANTS CREDIT ASSOCIATION, a Washington corporation and licensed collection agency,

Appellant,

v.

LITIGATION PRACTICE GROUP PC, a foreign professional service corporation; and PETER SCHNEIDER, an individual,

Respondents.

DWYER, J. — Litigation Practice Group (LPG) filed a lawsuit against

Merchants Credit Corporation (Merchants), a debt collection agency, on behalf of

David Trahan. Merchants thereafter filed third party claims against LPG for No. 84104-1-I/2

alleged violations of the Consumer Protection Act1 (CPA) and the federal Credit

Repair Organizations Act2 (CROA) premised on its assertion that LPG lacked the

authority to commence a lawsuit on Trahan’s behalf. Subsequently, on a motion

for summary judgment filed by LPG, the trial court entered an order dismissing

Merchants’ claims as frivolous and filed in bad faith and awarded LPG its

attorney fees and costs pursuant to RCW 4.84.185. Merchants appeals the entry

of the orders granting summary judgment and attorney fees to LPG. Holding that

the trial court did not err by ruling Merchants’ claims as frivolous, we affirm.

I

Trahan entered into a legal services agreement with LPG in December

2020. The agreement states that LPG will “investigate [Trahan’s] delinquent

accounts . . . up to and including the initiation of lawsuits on [his] behalf against

[his] creditors and their third-party debt collectors.”3 In May 2021, Trahan signed

a power of attorney, which permitted LPG to (1) contact his creditors regarding

past due accounts, (2) share personal information with his creditors, and (3) offer

settlement terms to resolve past due accounts on his behalf. The power of

attorney included a provision stating that “[t]he duties performed by [LPG] will be

limited in scope to the above-mentioned actions.”

On June 11, 2021, an order of default and default judgment was entered

against Trahan in the superior court. Merchants thereafter attempted to collect

on the judgment. On October 11, 2021, LPG provided Merchants with the power

1 Ch. 19.86 RCW. 2 15 U.S.C. §§ 1679-1679j. 3 The copy of the legal services agreement contained in our record, which LPG provided

to Merchants following the filing of Merchants’ third party complaint, is heavily redacted.

2 No. 84104-1-I/3

of attorney signed by Trahan, authorizing LPG to obtain documentation to

evaluate Trahan’s potential claims. LPG then served Merchants with a summons

and complaint, which alleged that Merchants had attempted to collect from

Trahan an amount of interest exceeding that permitted by the judgment, resulting

in violations of state and federal collection agency laws and the CPA.4

Merchants responded by offering to settle the claims. Referencing the

limitations set forth in the power of attorney, Merchants additionally requested

that LPG provide “a retention agreement reflecting that [LPG] had authorization

[from Trahan] to commence a lawsuit” in the matter.5

When settlement failed, Merchants filed a third party complaint wherein it

alleged that LPG had violated the CPA and the CROA by commencing the

lawsuit on Trahan’s behalf without his authorization. Merchants thereafter

offered to consider dismissing its third party claims against LPG on the condition

that LPG provide Merchants with evidence that it had authority to commence the

lawsuit. Additionally, Merchants stated, “[o]f course, we are also open to

discussing a global settlement of all claims in this lawsuit.”

On February 28, 2022, LPG filed a motion for summary judgment

dismissal of Merchants’ third party claims and for sanctions pursuant to CR 11

and RCW 4.84.185, based on the allegation that the claims were frivolous and

4 The complaint was filed in superior court on January 26, 2022. The parties’ briefing and the record indicate that the complaint was served on Merchants in December 2021, after, as described infra, Merchants sought to settle Trahan’s claims. 5 Peter Schneider, counsel for Trahan, responded in an e-mail to the request to provide a

retention agreement by stating that he had “never been asked to prove [his] authority to represent a client in [his] entire career practicing law.” He refused, at that time, to provide Merchants with such an agreement.

3 No. 84104-1-I/4

filed in bad faith. In support of its motion, LPG included a declaration signed by

Trahan’s counsel, Peter Schneider, stating that Trahan had authorized him to

commence the lawsuit. Schneider elaborated, “I signed the summons and

complaint pursuant to Rule 11, specifically because Plaintiff authorized me to file

this lawsuit.” He agreed to provide Trahan’s legal services agreement to the

court for in camera review. Finally, he stated he is a “Consumer Protection

Attorney” and that neither he nor LPG is a “Credit Repair Organization.”

Following a discovery conference, LPG provided to Merchants the

redacted copy of its legal services agreement with Trahan as well as a

declaration from Trahan. Trahan’s declaration stated that he had entered into

the legal services agreement that authorized LPG to initiate lawsuits against his

creditors on his behalf and, specifically, that he had authorized LPG to represent

him in this litigation. Merchants thereafter filed in the superior court a notice of

deposition seeking to depose Trahan on May 20, 2022.

On March 31, 2022, Merchants filed a CR 56(f) motion to continue LPG’s

motion for summary judgment in order to obtain Trahan’s deposition testimony

prior to providing a response to the summary judgment motion. Merchants

argued that it “needs an opportunity to cross-examine Mr. Trahan to show that

the self-serving declaration and attachment did not, in fact, authorize LPG to

bring this lawsuit, prior to this lawsuit being filed.” LPG opposed the motion for

continuance and renewed its request for “an award of sanctions against

Merchants and its counsel for filing a frivolous and meritless claim in bad faith,

4 No. 84104-1-I/5

and furthering the transgression through this motion.” On April 20, 2022, the trial

court denied Merchants’ CR 56(f) motion to continue.

On April 22, 2022, the trial court heard oral argument on LPG’s motion for

summary judgment dismissal of Merchants’ third party claims and for sanctions

against Merchants. The court noted that it was “taken aback that a third-party

complaint was filed,” rather than a motion for CR 11 sanctions, given Merchants’

allegation that LPG had initiated a lawsuit without authorization to do so.

Following oral argument, the court admonished Merchants, stating:

This Court has a rule, a basic rule. Try the case, not each other. That’s basic. It’s basic professionalism. It’s basic comportment that this Court expects of people who are -- are licensed and privileged to practice the law.

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