Minner v. Navient Solutions, LLC

CourtDistrict Court, W.D. New York
DecidedMay 26, 2023
Docket1:18-cv-01086
StatusUnknown

This text of Minner v. Navient Solutions, LLC (Minner v. Navient Solutions, LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Minner v. Navient Solutions, LLC, (W.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

JAMES L. MINNER, Plaintiff, v. DECISION AND ORDER 18-CV-1086S NAVIENT CORPORATION and NAVIENT SOLUTIONS, LLC, Defendants.

I. Introduction Before this Court is Plaintiff’s class action alleging Defendants violated New York General Business Law § 349, the Fair Credit Reporting Act, 15 U.S.C. § 1681s-2, and breached a contract in the servicing of his (and similarly situated person’s) student loans. Defendants moved to dismiss the initial version of the Complaint (Docket No. 6) and Minner cross-moved for leave to amend (Docket No. 10). This Court granted leave to amend while denying the Motion to Dismiss, Minner v. Navient Corporation, No. 18CV1086, 2020 WL 906628 (W.D.N.Y. Feb. 25, 2020) (Docket No. 13); familiarity with that Decision is presumed. Presently before this Court is Defendants’ Motion for Summary Judgment (Docket No. 73) dismissing the Third Amended Complaint (Docket No. 38). Prior to moving for summary judgment, Defendants Navient Solutions, LLC (or “NSL”) and Navient Corporation (“Navient Corp.”) moved to strike (Docket No. 72) Plaintiff’s expert report and testimony from Diane Sovereign (see Docket No. 71). This Court granted (Docket No. 87) the Motion to Strike (Docket No. 72) and now addresses Defendants’ Motion for Summary Judgment (Docket No. 73). For reasons stated below, this Summary Judgment Motion (Docket No. 73) is granted and the action is dismissed. II. Background A. Parties

James Minner is a federal student loan borrower with nine loans from the United States Department of Education (“DOE”) serviced first by Defendants’ predecessor, Sallie Mae, and later by Defendants (Docket No. 38, 3d Am. Compl. ¶¶ 1, 27, 30-61, 63-64, 169, Ex. B). Minner alleges a class of similarly situated “direct student loan borrowers from the federal government who had at least one federal loan serviced by Defendants and/or any of their predecessors between January 1, 2010 and the present that were reported to any credit reporting agency (or ‘CRA’) as delinquent or in default within thirty (30) days after a forbearance” (id. ¶ 23). Navient Corp.1 and NSL succeeded Sallie Mae as the federal student loan

servicers (id. ¶¶ 2, 8, 10, 13, 14, 58-62). As loan servicers, Minner alleges that Defendants are responsible for “managing borrower’s accounts, processing monthly payments, assisting borrowers to learn about, enroll in, and remain in alternative repayment plans” (id. ¶ 65). B. Prior Proceedings On September 13, 2018, Plaintiff James Minner sued Defendants in New York State Supreme Court (Docket No. 1, Notice of Removal, Ex. A). On October 4, 2018, Defendants removed the case to this Court (Docket No. 1). As noted above, Defendants

1 Navient Corp. is a holding company and does not engage in loan servicing, Docket No. 72, Defs. Memo. at 1 n.1. then moved to dismiss (Docket No. 6) and Plaintiff cross-moved for leave to amend (Docket No. 10). On February 25, 2020, this Court granted the Cross-Motion and denied the Motion to Dismiss, Minner, supra, 2020 WL 906628 (Docket No. 13). Plaintiff then amended the Complaint (Docket No. 14) and Defendants answered (Docket No. 17). On

July 10, 2020, Plaintiff amended the Complaint again (Docket No. 31, 2d Am. Compl.) and again on August 27, 2020 (Docket No. 38, 3d Am. Compl.). C. Third Amended Complaint (Docket No. 38) After taking out these student loans, Minner experienced long-term financial problems (Docket No. 38, 3d Am. Compl. ¶ 77). Defendants offered options for relief including income-driven repayment plans (or “IDR”) and forbearance (id. ¶ 69). Minner contends that Defendants inappropriately placed his loans in forbearance rather than IDR. Forbearance gives further time to repay an obligation or an agreement not to enforce a claim at its due date, Black’s Law Dictionary 644 (6th ed. 1990) (see also Docket No. 81, Pl. Aff. ¶ 3). Borrowers in forbearance accrue unpaid interest and the addition of

that unpaid interest to the principal of the loans and increasing the monthly payment (Docket No. 38, 3d Am. Compl. ¶¶ 81, 82, 106). It is the refinancing of the loan, Minner explains, is “typically not suitable for borrowers experiencing financial hardship or distress that is not temporary or short-term” (id. ¶ 80). Minner claims that borrowers in forbearance face “significant costs, which generally increase the longer the borrower is in forbearance” with accumulated unpaid interest and the addition of this interest to the underlying principal (id. ¶¶ 81-83). According to Defendants’ own website, forbearance was best for debtors experiencing only temporary financial distress (id. ¶¶ 78-80). IDR plans, however, are usually a better option for borrowers (like Minner) facing long-term financial hardship by avoiding the additional costs associated with forbearance (id. ¶ 84). Forbearance, however, was easier for Defendants to administer (id. ¶¶ 89-99).

Minner asserts Defendants also incentivized their customer-service representatives to push distressed borrowers into forbearance without exploring IDR plans (id. ¶ 89). Nevertheless, while Minner endured long-term hardship, Defendants told him that his loans should be placed in forbearance (id. ¶¶ 85, 77, 104) and Defendants then placed his loans (and those of similarly situated class members) in forbearance (id. ¶ 88). These borrowers experienced negative consequences from this assignment (id. ¶ 107). Forbearance, however, caused two major problems for Minner. First, he incurred additional costs with his loans. After being in forbearance status for some time, Minner switched to an IDR plan, but during the forbearance period interest accrued and was added to the principal balance of his loans (id. ¶ 106).

Second, Minner believed his credit reports contained errors about the status of these loans. Defendants told these borrowers that while their loans were in forbearance no default would occur but Minner alleges that upon removing these loans from forbearance Defendants misreported to consumer reporting agencies (or “CRAs”) defaults by these borrowers on their loans (id. ¶ 110). From these reports it appeared that these loans were never in forbearance and that Minner and class members had defaulted by failing to make payments during the forbearance period (id. ¶¶ 111, 114). Upon learning of these reports, Minner complained to the CRAs (id. ¶ 163). Minner alleges the CRAs informed Defendants that Minner disputed their reports (id. ¶ 164). Defendants failed to correct the reports stating that Minner had defaulted on his loans (id. ¶ 165). Meanwhile, Minner was working to pay off debt and improve his credit score before and during the forbearance period (id. ¶¶ 118-19). During the forbearance period, Minner

improved his credit score by 100 points (id. ¶ 119). This enabled him to qualify for a mortgage to refinance his home (id. ¶¶ 118-20). Credit reports indicated that Minner defaulted on his loans while they were in forbearance (id. ¶¶ 125-26). But after Defendants incorrectly reported that Minner had defaulted, Minner’s credit score fell approximately 120 points, and he was informed that he no longer qualified to refinance his mortgage (id. ¶¶ 124-25). Since Defendants’ incorrect reports, Minner has not been able to receive alternative financing for his mortgage (id. ¶ 126). In addition, Minner’s other lenders canceled several credit lines (id. ¶¶ 127-18). Minner references actions by the Consumer Financial Protection Bureau and

Attorneys General of four states that also accuse Defendants of steering other long-term hardship borrowers to forbearance and misrepresenting the status of their loans to CRAs (id. ¶¶ 86-87, 115-16, Ex. A). D.

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

Related

Erie Railroad v. Tompkins
304 U.S. 64 (Supreme Court, 1938)
Klaxon Co. v. Stentor Electric Manufacturing Co.
313 U.S. 487 (Supreme Court, 1941)
Adickes v. S. H. Kress & Co.
398 U.S. 144 (Supreme Court, 1970)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Elmore v. North Fork Bancorporation, Inc.
325 F. Supp. 2d 336 (S.D. New York, 2004)
Taylor v. City of New York
269 F. Supp. 2d 68 (E.D. New York, 2003)
Matter of Allstate Ins. Co.(stolarz-Njm)
81 N.Y.2d 219 (New York Court of Appeals, 1993)
In re the Arbitration between Allstate Insurance & Stolarz
613 N.E.2d 936 (New York Court of Appeals, 1993)
Keefe v. New York Law School
71 A.D.3d 569 (Appellate Division of the Supreme Court of New York, 2010)
Ford v. Reynolds
316 F.3d 351 (Second Circuit, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
Minner v. Navient Solutions, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/minner-v-navient-solutions-llc-nywd-2023.