Morgan v. Bank of America NA

CourtDistrict Court, E.D. Washington
DecidedJuly 14, 2020
Docket2:20-cv-00157
StatusUnknown

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

Bluebook
Morgan v. Bank of America NA, (E.D. Wash. 2020).

Opinion

1 2 FILED IN THE U.S. DISTRICT COURT 3 EASTERN DISTRICT OF WASHINGTON Jul 14, 2020 4 SEAN F. MCAVOY, CLERK 5

6 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 7 DANIEL MORGAN, an individual, and 8 all those similarly situated, NO. 2:20-CV-00157-SAB 9 Plaintiff, 10 ORDER DENYING v. DEFENDANT’S MOTION TO 11 DISMISS AND REMANDING 12 BANK OF AMERICA, N.A., TO SUPERIOR COURT

13 Defendant. 14 15 Before the Court is Defendant’s Fed. R. Civ. P. 12(b)(1) and 12(b)(6) 16 Motion to Dismiss, ECF No. 3. Having considered the parties’ briefs and oral 17 arguments and the relevant caselaw, the Court DENIES Defendant’s Motion to 18 Dismiss and GRANTS Plaintiff’s Construed Motion to Remand the case to the 19 Spokane County Superior Court. 20 BACKGROUND 21 This case stems from a credit card debt Plaintiff incurred with FIA Card 22 Services, N.A., which initiated a collection action against Plaintiff in the Spokane 23 County District Court in 2012. While the action was ongoing, FIA Card Services 24 merged into Defendant in 2014, and Defendant continued to litigate under FIA’s 25 name “for more than half a decade.” ECF No. 5 at 8. Plaintiff alleges that 26 Defendant’s collection activities violated the Fair Debt Collection Practices Act 15 27 U.S.C. § 1692 et seq. (“FDCPA”) in three ways. First, on or about February 23, 28 2015, the Spokane County District Court issued a Notice for Dismissal for Want of 1 Prosecution, effective after 30 days, unless Defendant undertook timely action as 2 specified in the Notice. Defendant did not undertake timely action as specified, but 3 instead filed two Motions for Summary Judgment on or about June 19, 2017 and 4 October 31, 2019, respectively. Plaintiff alleges that Defendant attempted to collect 5 money from Plaintiff more than 30 days after the Spokane County District Court’s 6 February 23, 2015 Notice, in violation of 15 U.S.C. §§ 1692e(2) and 1692e(5). 7 Second, in the debt collection complaint, Defendant claimed that Plaintiff owed 8 $13,559.85 and Plaintiff’s last payment was on October 4, 2010. But in its October 9 31, 2019 Motion for Summary Judgment, Defendant averred that Plaintiff’s last 10 payment was made on October 18, 2013 in the amount of $50. Plaintiff argues that 11 Defendant did not credit any payments to the $13,559.85 debt since October 4, 12 2010. Plaintiff alleges that Defendant violated 15 U.S.C. § 1692f(1) by attempting 13 to collect $13,559.85, the full amount alleged due on October 4, 2010, even as 14 Defendant acknowledged Plaintiff’s last payment was on October 18, 2013 in the 15 amount of $50. Third, Plaintiff alleges Defendant violated 15 U.S.C. § 1692e(14) 16 by using the name “FIA Card Services,” a name other than its own true name, in 17 debt collection proceedings. 18 Plaintiff filed his Complaint in the Spokane County Superior Court on 19 March 18, 2020. On April 16, Defendant removed this case to federal court on the 20 basis of federal question jurisdiction. On May 4, Defendant moved to dismiss 21 Plaintiff’s claims with prejudice pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6), 22 arguing that Plaintiff lacks Article III standing, that Defendant was not a “debt 23 collector” under the FDCPA, and that Plaintiff’s claims are time-barred by the 24 FDCPA’s one-year statute of limitations. In response, Plaintiff conceded that he 25 “allege[d] nowhere that he suffered an injury that would satisfy Article III,” which 26 was “precisely why Plaintiff filed his case in state court, rather than in this Court.” 27 Instead, Plaintiff requested the Court to deny the Motion, remand the case to state 28 1 court, and award attorney fees and costs for work performed in response to 2 Defendant’s removal. 3 STANDARD OF REVIEW 4 When reviewing a motion to dismiss, a district court must accept as true all 5 material allegations in the complaint and must construe the complaint in the 6 nonmovant’s favor. Bernhardt v. Cty. of Los Angeles, 279 F.3d 862, 867 (9th Cir. 7 2002). A plaintiff needs only to plead “general factual allegations” of injury to 8 survive a motion to dismiss, as opposed to the “specific facts” needed to survive a 9 motion for summary judgment. Lujan v. Defenders of Wildlife, 504 U.S. 555, 561 10 (1992). 11 DISCUSSION 12 1. Standing and Subject Matter Jurisdiction 13 At issue here is whether Plaintiff has standing to proceed in federal court—a 14 forum this Court notes Plaintiff did not choose and which he is in against his will. 15 “Standing to sue is a doctrine rooted in the traditional understanding of a case or 16 controversy” under Article III of the Constitution. Spokeo, Inc. v. Robins, 136 S. 17 Ct. 1540, 1549 (2016). “The doctrine developed in our case law to ensure that 18 federal courts do not exceed their authority as it has been traditionally understood.” 19 Id. The “irreducible constitutional minimum of standing” consists of three 20 elements, all of which the party invoking federal jurisdiction bears the burden of 21 establishing: first, the plaintiff must have suffered an “injury in fact”; second, there 22 must be a causal connection between the injury and the conduct complained of; 23 and third, the injury will likely be “redressed by a favorable decision.” Lujan, 504 24 U.S. at 560-561. 25 Relevant here is the injury-in-fact element. To establish this element, the 26 plaintiff must have suffered “an invasion of a legally protected interest” that is 27 “concrete and particularized” and “actual or imminent, not conjectural or 28 hypothetical.” Id. at 560. A plaintiff does not “automatically satisf[y] the injury-in- 1 fact requirement whenever a statute grants a person a statutory right and purports 2 to authorize that person to sue to vindicate that right.” Spokeo, 136 S. Ct. at 1549. 3 In other words, “Article III standing requires a concrete injury even in the context 4 of a statutory violation.” Id. For that reason, a plaintiff cannot “allege a bare 5 procedural violation, divorced from any concrete harm, and satisfy the injury-in- 6 fact requirement of Article III.” Id. 7 Here, both parties agree that Plaintiff alleges no concrete injury and thus 8 lacks Article III standing. ECF No. 3 at 7-10; ECF No. 5 at 3-4. The Court has no 9 reason to find otherwise. As the party invoking federal jurisdiction, the burden was 10 on Defendant, not Plaintiff, to prove that all the elements of federal jurisdiction 11 were satisfied upon removal. Defendant’s attempt to invoke federal jurisdiction for 12 purposes of removal and then argue for dismissal based on the lack of standing—a 13 fundamental element of this Court’s jurisdiction—does not satisfy its burden. 14 Accordingly, the Court finds that it lacks jurisdiction to consider this case. 15 2. Dismissal or Remand 16 In absence of standing, the Court next considers whether this case should be 17 dismissed or remanded to state court. 18 Where standing is absent in a removed case, “the case shall be remanded.” 19 28 U.S.C. § 1447

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Morgan v. Bank of America NA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morgan-v-bank-of-america-na-waed-2020.