National Merchants Assn. v. Commercial Bank of Cal. CA2/8

CourtCalifornia Court of Appeal
DecidedJanuary 12, 2026
DocketB341687
StatusUnpublished

This text of National Merchants Assn. v. Commercial Bank of Cal. CA2/8 (National Merchants Assn. v. Commercial Bank of Cal. CA2/8) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
National Merchants Assn. v. Commercial Bank of Cal. CA2/8, (Cal. Ct. App. 2026).

Opinion

Filed 1/12/26 National Merchants Assn. v. Commercial Bank of Cal. CA2/8 NOT TO BE PUBLISHED IN THE OFFICIAL REPORTS

California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115.

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT

DIVISION EIGHT

NATIONAL MERCHANTS B341687 ASSOCIATION, (Los Angeles County Plaintiff and Appellant, Super. Ct. No. 21STCV44674)

v.

COMMERCIAL BANK OF CALIFORNIA,

Defendant and Respondent.

APPEAL from a judgment of the Superior Court of Los Angeles County. Joseph Lipner, Judge. Affirmed. Consumer Equity Legal and Casey C. Daggett for Plaintiff and Appellant. Hennelly & Grossfeld, Michael G. King and Thomas H. Case for Defendant and Respondent.

___________________________ SUMMARY Plaintiff National Merchants Association appeals from an award of attorney fees to defendant Commercial Bank of California after plaintiff voluntarily dismissed its complaint prior to trial. Plaintiff alleges that all of its claims were based on the contract between the parties, and therefore an award of attorney fees is prohibited by Civil Code section 1717.1 We find no error in the trial court’s conclusion that Commercial Bank of California was the prevailing party and entitled to recover its attorney fees incurred in defending the tort claims alleged against it. Accordingly, we affirm. FACTUAL AND PROCEDURAL BACKGROUND Plaintiff National Merchants Association, Inc. (NMA) sued Commercial Bank of California (Bank) in connection with a failed business relationship. The operative first amended complaint contains seven causes of action. 1. The First Amended Complaint In the first amended complaint, NMA alleged that it is in the business of providing electronic payment processing solutions to merchants. NMA is required to contract with a sponsor bank that is registered with the credit card brand (such as Visa or MasterCard) to settle the proceeds of the electronic transactions submitted by NMA’s merchants. The sponsor bank is referred to as an “acquirer.” In this case, Bank is the acquirer. According to the complaint, NMA’s “niche” included “its proprietary underwriting and account monitoring to effectively manage processing payments for Merchants engaged in the sale of various products online on a trial basis, including

1 All further undesignated statutory references are to the Civil Code unless otherwise stated.

2 nutraceuticals, which includes products such as skin creams and vitamin supplements.” There was “naturally a higher risk of return involved with such Merchant’s electronic transactions,” as well as a risk of “friendly fraud” referred to as “chargebacks.” In late 2016, NMA began negotiations for Bank “to serve as NMA’s Acquirer.” On March 1, 2017, the parties entered into a “Merchant Marketing and Processing Agreement” (the 2017 Agreement) based upon Bank’s representations, “including that it could adequately onboard and settle NMA’s growing portfolio of high-risk online Merchants, specifically consisting largely of Nutra Merchants [Merchants that sold nutraceuticals online].” “At that time” the parties discussed “that though Nutra Merchants were prohibited under [Bank’s] restricted merchant types list, [Bank] relying upon NMA’s Proprietary Systems to underwrite, approve, onboard, and monitor risk for Nutra Merchants would remove Nutra Merchants from its restricted list and approve Nutra Merchants qualified by NMA.” The 2017 Agreement provides: “In the event of any dispute arising out of or in connection with this Agreement, the prevailing Party shall be entitled to recover its reasonable attorney’s fees and court costs in addition to any other recovery.” After a test period, “at the time Parties’ business relationship was scheduled to go live, [Bank] inexplicably notified NMA that [Bank] would not accept any applications for payment processing services from Nutra Merchants referred by NMA.” This was “a 180 degree about face from the [Bank] Representations.” In late 2017, NMA “was able to satisfy [Bank’s] concerns regarding approving Nutra Merchants to overcome its overly stringent policies and complete prohibition on acting as an

3 Acquirer.” Although NMA was able to onboard some Merchants and submit transactions, “NMA sill continued to have issues with its Merchants and suffered losses due to [Bank] ignoring NMA’s advice and mismanaging the relationship.” NMA alleged that in late 2018, Bank “took a different route to place NMA under further economic duress by attempting to steal NMA’s Proprietary Systems, all unbeknownst to NMA.” Bank gained access to NMA’s confidential information, including its customer list, and “offered NMA’s portfolio for sale to various ISOs [independent sales offices].” Other allegations involved Bank’s “interfere[nce] with NMA’s contractual relationship” with certain merchants and “misappropriating NMA’s Proprietary Systems and confidential information.” In May 2019, a Union Bank entity sued NMA in a separate lawsuit in connection with a loan agreement. NMA alleged that the Union Bank lawsuit was filed because NMA was “overleveraged,” and this was “primarily due to considerably lower revenue” caused by Bank’s “refusing to board merchant accounts from NMA and its failure to fulfill other of the [Bank] Representations.” In June 2019, a receiver was installed to take control of NMA. On June 25, 2019, Bank sent a notice of termination of the parties’ 2017 Agreement, and Bank “froze all funds due and owing to NMA” under the 2017 Agreement. In July 2019, Bank and the receiver for NMA entered into a Temporary Merchant Marketing and Processing Agreement (the 2019 Agreement). The 2019 Agreement increased the rates and fees charged to NMA under the 2017 Agreement by 150 percent. In April 2020, “[o]nce NMA satisfied its obligations to Union Bank and the Receivership was dissolved, [Bank] forced

4 NMA to execute an Amended and Restated Temporary Merchant Marketing and Processing Agreement” (the 2020 Amended Agreement). At the time, NMA alleged that it “had been placed under such economic duress by [Bank’s] actions that it had no choice but to enter” the 2020 Amended Agreement because Bank “had threatened to entirely disable NMA from servicing the Merchants that remained in its portfolio.” NMA alleged that Bank “continues to delay funding revenue due and owing to NMA”; “continues to attempt to interfere with NMA’s existing business relationship with its new Acquirer”; and “continues to misappropriate NMA’s trade secrets . . . and interfere with NMA’s contractual relations and prospective economic advantage by soliciting NMA’s customers.” NMA asserted seven causes of action for breach of written agreement (the 2017 Agreement), breach of contract (the 2019 Agreement), breach of the covenant of good faith and fair dealing, unjust enrichment, unfair business practices, promissory fraud, and rescission. 2. Procedural Background and Motion for Attorney Fees NMA filed the original complaint on December 8, 2021, and the first amended complaint on August 19, 2022. The parties’ 2017 Agreement provides that any disputes would be heard by a referee, and that the referee “may award attorneys’ fees and reimbursement of the referee and reference proceeding fees and costs to the prevailing Party, whereupon all referee and reference proceeding fees and charges will be payable by the non-prevailing Party (as so determined by the referee).” In May 2022, the trial court granted Bank’s motion compelling judicial reference and

5 appointed Hon. Stephen E. Haberfeld (Ret.) of JAMS as the judicial referee.

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Bluebook (online)
National Merchants Assn. v. Commercial Bank of Cal. CA2/8, Counsel Stack Legal Research, https://law.counselstack.com/opinion/national-merchants-assn-v-commercial-bank-of-cal-ca28-calctapp-2026.