Miller v. Stuart

CourtDistrict Court, E.D. Louisiana
DecidedFebruary 13, 2025
Docket2:24-cv-02890
StatusUnknown

This text of Miller v. Stuart (Miller v. Stuart) is published on Counsel Stack Legal Research, covering District Court, E.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miller v. Stuart, (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

ROBBIN Y MILLER CIVIL ACTION

VERSUS NO. 24-2890

ANDREW STUART ET AL SECTION “B”(2)

ORDER AND REASONS

Before the Court is defendants Andrew Stuart and TD Auto Finance’s motion to dismiss plaintiff’s complaint (Rec. Doc. 3). Plaintiff did not file an opposition to the motion, so we will consider it unopposed. For the following reasons, IT IS ORDERED that defendants Andrew Stuart and TD Auto Finance’s motion to dismiss plaintiff’s complaint (Rec. Doc. 3) be GRANTED IN PART, in accordance with this Order. Plaintiff’s claims based against Andrew Stuart are hereby DISMISSED WITH PREJUDICE. IT IS FURTHER ORDERED that plaintiff shall file an amended complaint with respect to her standing to assert claims against defendant TD Auto Finance and specific facts supporting her claims of breach of contract, violation of La. R.S. § 10:9-210, and negligence per se, no later than February 28, 2025. Failure to timely amend the complaint will lead to the dismissal of the action without future notice. FACTUAL BACKGROUND AND PROCEDURAL HISTORY

This is a 28 U.S.C. § 1332 diversity jurisdiction claim filed by plaintiff Robin Y. Miller (“Miller”). Rec. Doc. 1 at 6 ¶ 5. Contending her vehicle’s lienholder ignored her August 2024 demand, pursuant to La. Rev. Stat. § 10:9-210, requesting an accounting of the status of the secured obligation, plaintiff Miller expressly brings her pro se complaint against Andrew Stuart (“Stuart”) and TD Auto Finance (“TD Auto”) for (1) breach of duty of good faith and fair dealing, (2) violation of La. Rev. Stat. § 10:9-210, and (3) negligence per se. Rec. Doc. 1 at 7 ¶¶ 12-20. Plaintiff alleges that she entered a secured transaction with defendants for the financing of a 2024 GMC Sierra 1500 (“Vehicle”) in May of 2024. Rec. Doc. 1 at 6 ¶ 7; Rec. Doc. 3-1 at 2-6. Nonetheless, although the contractual relationship was established in May, Miller asserts that she requested an

accounting of the status of her secured obligation around August 2024 but was ignored. Rec. Doc. 1 at 6 ¶ 8. Miller avers that defendants’ failure to address her request caused her to suffer financial harm, emotional distress, and the inability to resolve or challenge inaccuracies related to the loan. Defendant now moves to dismiss plaintiff’s complaint. See Rec. Doc. 3. Their motion has gone unopposed by pro se plaintiff Miller. LAW AND ANALYSIS A. Motion to Dismiss Standard i. Subject Matter Jurisdiction Throughout the instant motion, defendants base their argument for dismissal upon Rule 12(b)(6). See Rec. Doc. 3. Nonetheless, the defendants’ motion to dismiss also raises the issue of

plaintiff Miller’s standing to assert her claims. Id. “A motion to dismiss that attacks a party’s standing is a jurisdictional matter.” See In re Wilson, 527 B.R. 253, 255 (Bankr. N.D. Tex. 2015) (quoting Broadhollow Funding LLC v. Bank of Am., N.A., 390 B.R. 120, 128 (Bankr. D. Del. 2008)). “Standing goes to the ‘case or controversy’ limitation on federal court jurisdiction . . . and a plaintiff’s lack of standing ‘robs the court of jurisdiction to hear the case.’” In re Hunt, 149 B.R. 96, 99 (Bankr. N.D. Tex. 1992) (citations omitted). Challenges to a plaintiff’s standing to bring a claim may be brought under 12(b)(1). Fed. R. Civ. P. 12(b)(1). “Lack of subject matter jurisdiction may be found in any one of three instances: (1) the complaint alone; (2) the complaint supplemented by undisputed facts evidenced in the record; or (3) the complaint supplemented by undisputed facts plus the court’s resolution of disputed facts. Id. (citing Barrera-Montenegro v. United States, 74 F.3d 657, 659 (5th Cir. 1996)). “The burden of proof for a Rule 12(b)(1) motion to dismiss is on the party asserting jurisdiction.” Id. (citing McDaniel v. United States, 899 F.Supp. 305, 307 (E.D. Tex. 1995); Menchaca v.

Chrysler Credit Corp., 613 F.2D 507, 511 (5th Cir. 1980)). Accordingly, here, plaintiff Miller bears the burden of proof that jurisdiction exists. To survive a motion to dismiss under Rule 12(b)(1) based on lack of Article III standing, a plaintiff must establish: “(1) an injury in fact, (2) a sufficient causal connection between the injury and the conduct complained of, and (3) a likel[ihood] that the injury will be redressed by a favorable decision.” Susan B. Anthony List v. Driehaus, 573 U.S. 149, 157-58 (2014) (internal quotations omitted). The “manner and degree of evidence required” to prove standing is proportionate to when the inquiry question standing occurs during the litigation. When a Rule 12(b)(1) motion is filed in conjunction with other Rule 12 motions, as here, the Court should consider the “jurisdictional attack before addressing any attack on the merits.” Ramming v. United

States, 281 F.3d 158, 161 (5th Cir. 2001) (citing Hitt v. Pasadena, 561 F.2d 606, 608 (5th Cir. 1977)). ii. Failure to State a Claim Rule 12(b)(6) of the Federal Rules of Civil Procedure allows a party to move for dismissal of a complaint for failure to state a claim upon which relief can be granted. To survive a motion to dismiss under Rule 12(b)(6), a plaintiff’s complaint “must contain ‘enough facts to state a claim to relief that is plausible on its face.’” Varela v. Gonzales, 773 F.3d 704, 707 (5th Cir. 2014) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). In other words, a plaintiff’s “[f]actual allegations must be enough to raise a right to relief above the speculative level.” Twombly, 550 U.S. at 555 (discussing Fed. R. Civ. P. 8(a)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 556 U.S. at 556).

When deciding whether a plaintiff has met its burden, a court “accept[s] all well-pleaded factual allegations as true and interpret[s] the complaint in the light most favorable to the plaintiff, but ‘[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements’ cannot establish facial plausibility.” Snow Ingredients, Inc. v. SnoWizard, Inc., 833 F.3d 512, 520 (5th Cir. 2016) (quoting Iqbal, 556 U.S. at 678) (some internal citations and quotation marks omitted). Plaintiffs must “nudge [] their claims across the line from conceivable to plausible.” Twombly, 550 U.S. at 570. A complaint does not meet the plausibility standard “if it offers only labels and conclusions, or a formulaic recitation of the elements of a cause of action.” Whitley v. Hanna, 726 F.3d 631, 638 (5th Cir. 2013) (internal quotation marks omitted) (citing Twombly, 556 U.S. at 555).

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Miller v. Stuart, Counsel Stack Legal Research, https://law.counselstack.com/opinion/miller-v-stuart-laed-2025.