Moses v. Wells Fargo Bank, N.A.

CourtDistrict Court, E.D. Louisiana
DecidedAugust 12, 2025
Docket2:25-cv-00546
StatusUnknown

This text of Moses v. Wells Fargo Bank, N.A. (Moses v. Wells Fargo Bank, N.A.) 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
Moses v. Wells Fargo Bank, N.A., (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

MICHAEL MOSES, ET AL. CIVIL ACTION

VERSUS NO: 25-546

WELLS FARGO BANK, N.A. SECTION: "A" (5)

ORDER AND REASONS The following motion is before the Court: Motion to Dismiss for Failure to State a Claim (Rec. Doc. 7) filed by the defendant, Wells Fargo Bank, N.A. (“Wells Fargo”). The plaintiffs, Dr. Michael Moses and Kathy Moses (“Plaintiffs”), oppose the motion. The motion, submitted for consideration on July 23, 2025, is before the Court on the briefs without oral argument. For the reasons that follow, the motion is GRANTED IN PART AND DENIED IN PART. I. Background Plaintiffs have brought this action against Wells Fargo alleging that Wells Fargo reneged on a legally binding agreement to lend them money at a locked in interest rate. Plaintiffs had sought financing from Wells Fargo to build their dream vacation home in Pensacola, Florida. In 2022 Plaintiffs began working with a Wells Fargo mortgage consultant, who advised them that for a fee Plaintiffs could lock in a great rate. (Rec. Doc. 1, Complaint ¶ 10). At the time interest rates were at historic lows and predicted to increase. On July 19, 2022, Plaintiffs paid Wells Fargo a fee of $15,750.00 to lock in the interest rate of 3.750% for 540 days, or until December 27, 2023. (Id. ¶ 13). The Interest

Page 1 of 16 Rate Lock Agreement is dated July 7, 2022. (Rec. Doc. 7-2, Exhibit A). Plaintiffs allege that Wells Fargo made representations to them that the loan that they hoped to attain could be used at the Pensacola property. (Complaint ¶ 11).

Plaintiffs’ ownership of the Pensacola property was a “leasehold” because beachfront land near Pensacola Beach is federally owned and administered by the State of Florida. (Id. ¶ 17). Wells Fargo did not offer construction loans but Plaintiffs allege that Wells Fargo advised them that they could obtain a construction loan with another bank (which they did) and then later refinance the debt with a loan from Wells Fargo at the favorable rate that they had locked in. (Id. ¶ 14).

On September 8, 2022, Plaintiffs received a Commitment Letter (Rec. Doc. 7-3, Exhibit B), from Wells Fargo stating that their loan application had been approved. (Complaint ¶ 19). Construction began in November 2022 but took longer than anticipated. (Id. ¶ 18). Plaintiffs allege that throughout the course of construction they obtained several extensions of their original Interest Rate Lock Agreement and were assured that Wells Fargo would provide a loan at the locked in rate. (Id. ¶ 19).

Construction was completed in June 2024 and by this time interest rates had risen significantly. (Id. ¶ 21). Plaintiffs allege that Wells Fargo began a concerted campaign of fraud and ill practice whereby it sought to prohibit the loan from closing at the locked in rate that it was contractually obligated to honor. (Id. ¶ 23). Plaintiffs allege that Well Fargo repeatedly postponed closing on the loan as one-by-one it sought to

Page 2 of 16 invoke each of the exceptions listed in the rate lock agreement that would allow Wells Fargo to avoid lending money at the locked in rate. (Id. ¶ 25). In May of 2024 Wells Fargo informed Plaintiffs that it would not be able to lend

them money at the locked in rate because Dr. Moses’s credit score had dropped. (Complaint ¶ 51). Although his credit score had in fact dropped, the only activity reflected on Dr. Moses’s credit report was the repeated credit checks initiated by Wells Fargo every three months for a period of nearly two years. (Id. ¶ 53). Plaintiffs allege that prior to citing the dropped credit score, Wells Fargo attempted to renege on the rate lock agreement by claiming that the property had appraised too low and by suggesting that Plaintiffs did not have sufficient income to obtain the loan. (Id. ¶¶ 35, 46). In fact,

the first post-construction appraisal had come back significantly lower than anticipated. Next Wells Fargo told Plaintiffs that it was uncomfortable providing the loan because the property was a leasehold. (Id. ¶ 57). Plaintiffs allege that Wells Fargo knew all along that the property was a leasehold and that Wells Fargo had routinely provided loans for property on leased Pensacola Beach land.1 (Id. ¶ 58). In early December of 2024 Plaintiffs were informed that Wells Fargo was denying

the loan. (Id. ¶ 60). The denial letter from Wells Fargo cited three reasons for the denial: amount of credit required is too high relative to your income, amounts owed are too high

1 Wells Fargo argues that loan decisions regarding other borrowers’ plans for Pensacola Beach are irrelevant and the Court agrees. Even though the leasehold aspect of the property was one problem that Wells Fargo had in extending the loan, numerous factors go into the loan decision. Thus, Plaintiffs will not be allowed to conduct discovery into other borrowers’ transactions with Wells Fargo.

Page 3 of 16 relative to your income, and property type does not meet investor/lender requirements.2 (Id. ¶ 61). Plaintiffs contend that Wells Fargo simply did not want to honor the rate lock agreement given that interest rates had risen precipitously so it fraudulently and

intentionally broke its contract with them. (Id. ¶ 64). Plaintiffs filed this lawsuit alleging breach of contract, fraud/fraudulent inducement, unfair trade practices, negligent misrepresentation, and in the alternative, detrimental reliance. Plaintiffs seek a litany of damages. (Complaint ¶ 104). Plaintiffs allege that due to Wells Fargo’s actions they paid interest on their extremely high- interest construction loan for the several months that Wells Fargo strung them along until finally denying their loan application. (Id. ¶ 68). The loan that Plaintiffs ultimately

obtained (from another bank) had far less favorable terms than the loan that Plaintiffs had been promised by Wells Fargo. (Id. ¶ 67). Wells Fargo’s position is that the Interest Rate Lock Agreement and the Commitment Letter were premised on several conditions and that when it came time to close on the loan Plaintiffs simply did not meet them. Therefore, according to Wells Fargo, it had no obligation to give them a loan at the locked in rate or at any rate for that

matter, and that the refusal to give them a loan is not actionable under any of the legal theories that Plaintiffs rely upon in their complaint. Plaintiffs’ position is that Wells Fargo’s cited reasons for ultimately denying the loan were pretexts for the real reason that Wells Fargo denied the loan—interest rates

2 Plaintiffs have not provided a copy of the denial letter.

Page 4 of 16 had risen precipitously, and the locked in rate was no longer a good deal for the bank. Plaintiffs argue that the pretextual reasons were either inaccurate, manipulated by Wells Fargo, or known by Wells Fargo all along.

Via the instant Rule 12(b)(6) motion, Wells Fargo moves to dismiss the complaint in its entirety. The parties’ arguments are addressed below. II. Discussion The central issue in a Rule 12(b)(6) motion to dismiss is whether, in the light most favorable to the plaintiff, the complaint states a valid claim for relief. Gentilello v. Rege, 627 F.3d 540, 544 (5th Cir. 2010) (quoting Doe v. MySpace, Inc., 528 F.3d 413, 418 (5th Cir. 2008)). To avoid dismissal, a plaintiff must plead sufficient facts to Astate a

claim for relief that is plausible on its face.@ Id. (quoting Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009)). AA 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.@ Id.

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