Natour v. BANK OF AMERICA, N.A.

District Court, E.D. Texas·Decided June 22, 2022·No. 4:21-cv-00331·Unknown

Opinion

United States District Court EASTERN DISTRICT OF TEXAS SHERMAN DIVISION

NICK NATOUR and ENCLARE, LLC, § § § Civil Action No. 4:21-CV-00331 v. § Judge Mazzant § BANK OF AMERICA, N.A., et al. § § AMENDED MEMORANDUM OPINION AND ORDER1 Pending before the Court is Defendant Bank of America, N.A.’s Motion for Summary Judgment (Dkt. #136). Having considered the motion and relevant pleadings, the Court finds the motion should be GRANTED. BACKGROUND Plaintiff Nick Natour (“Natour”) owns a Dallas restaurant called Mignon. Mignon operates under the legal name Enclare, LLC (“Enclare”). On September 25, 2019, Enclare entered a Merchant Processing Application and Agreement (the “Agreement”) with First Data Merchant Services LLC (“First Data”), which enabled Enclare to accept payment through credit cards from its restaurant customers. In March of 2020, Ali Hamdan (“Hamdan”) placed a catering order with Mignon that cost $170,528.35 (the “Order”). Hamdan used a Bank of America debit card, across two transactions, to pay for the Order (the “Transactions”). The Transactions were initially declined due to fraud concerns. Notably, the account associated with the Bank of America debit card was closed in April of 2018 (the “Bank of America Account”). Natour allegedly spoke to Defendant Bank of America, N.A. (“Bank of America”),

1 The Court enters this Amended Memorandum Opinion and Order to correct a clerical error on p. 9 infra. obtained a valid authorization code for the Transactions, and proceeded with the sale. However, eight days later, Plaintiffs’ account statement from One Payment (the “One Payment Account”) reflected an adjustment (the “Adjustment”) of the same amount of the Transactions under the heading “Electronic Deposit Rejects.” As a result of the Adjustment, Plaintiffs never received payment for the Order.

On February 9, 2022, Bank of America moved for summary judgment, asserting Plaintiffs have no evidence to sustain their claims for violation of the Electronic Funds Transfer Act, conversion, violation of the Texas Theft Liability Act, and civil conspiracy (Dkt. #126). Plaintiffs responded on February 28, 2022 (Dkt. #142). Bank of America replied on March 7, 202 (Dkt. #145). LEGAL STANDARD The purpose of summary judgment is to isolate and dispose of factually unsupported claims or defenses. Celotex Corp. v. Catrett, 477 U.S. 317, 323–24 (1986). Summary judgment is proper under Rule 56(a) of the Federal Rules of Civil Procedure “if the movant shows that there is no

genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” FED. R. CIV. P. 56(a). A dispute about a material fact is genuine when “the evidence is such that a reasonable jury could return a verdict for the nonmoving party.” Anderson v. Liberty Lobby Inc., 477 U.S. 242, 248 (1986). Substantive law identifies which facts are material. Id. The trial court “must resolve all reasonable doubts in favor of the party opposing the motion for summary judgment.” Casey Enters., Inc. v. Am. Hardware Mut. Ins. Co., 655 F.2d 598, 602 (5th Cir. 1981). The party seeking summary judgment bears the initial burden of informing the court of its motion and identifying “depositions, documents, electronically stored information, affidavits or declarations, stipulations (including those made for purposes of the motion only), admissions, interrogatory answers, or other materials” that demonstrate the absence of a genuine issue of material fact. FED. R. CIV. P. 56(c)(1)(A); Celotex, 477 U.S. at 323. If the movant bears the burden of proof on a claim or defense for which it is moving for summary judgment, it must come forward with evidence that establishes “beyond peradventure all of the essential elements of the claim or defense.” Fontenot v. Upjohn Co., 780 F.2d 1190, 1194 (5th Cir. 1986). Where the nonmovant

bears the burden of proof, the movant may discharge the burden by showing that there is an absence of evidence to support the nonmovant’s case. Celotex, 477 U.S. at 325; Byers v. Dall. Morning News, Inc., 209 F.3d 419, 424 (5th Cir. 2000). Once the movant has carried its burden, the nonmovant must “respond to the motion for summary judgment by setting forth particular facts indicating there is a genuine issue for trial.” Byers, 209 F.3d at 424 (citing Anderson, 477 U.S. at 248–49). A nonmovant must present affirmative evidence to defeat a properly supported motion for summary judgment. Anderson, 477 U.S. at 257. Mere denials of material facts, unsworn allegations, or arguments and assertions in briefs or legal memoranda will not suffice to carry this burden. Rather, the Court requires

“significant probative evidence” from the nonmovant to dismiss a request for summary judgment. In re Mun. Bond Reporting Antitrust Litig., 672 F.2d 436, 440 (5th Cir. 1982) (quoting Ferguson v. Nat’l Broad. Co., 584 F.2d 111, 114 (5th Cir. 1978)). The Court must consider all of the evidence but “refrain from making any credibility determinations or weighing the evidence.” Turner v. Baylor Richardson Med. Ctr., 476 F.3d 337, 343 (5th Cir. 2007). ANALYSIS Bank of America contends all of Plaintiffs’ claims against it should be dismissed for the total lack of any supporting evidence. Plaintiffs have brought claims for violation of the Electronic Fund Transfer Act, 15 U.S.C. § 1693 (“EFTA”), conversion, violation of the Texas Theft Liability Act, and civil conspiracy against Bank of America. The Court will begin its analysis with the EFTA claim. I. Electronic Fund Transfer Act Bank of America argues Plaintiffs’ claim for violation of the EFTA fails as a matter of law because the EFTA is a consumer protection act and Plaintiffs are not “consumers” within the

definition of the statute. Further, Bank of America contends no account existed at the time of the Transactions.2 Plaintiffs assert Natour is a consumer and that an account did exist at the time of the Transactions. A. Consumer The EFTA defines “consumer” as “a natural person.” 15 U.S.C. § 1693a(6). “Corporations or other business entities are not ‘consumers’ for the purposes of EFTA.” Ironforge.com v. Paychex, Inc., 747 F. Supp. 2d 384, 402 (W.D.N.Y. 2010) (citing Kashanchi v. Texas Com. Med. Bank, N.A., 703 F.2d 936, 939–42 (5th Cir. 1983). Thus, there is no doubt Enclare is not a consumer. Id. Plaintiffs appear to concede this point by only addressing whether Natour qualifies

as a consumer. Bank of America argues Natour is not a consumer because of the nature of his involvement in the Transactions. Specifically, Natour was acting as “a merchant or business who sold goods to the consumer” rather than for personal, family, or household purposes (Dkt.

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Natour v. BANK OF AMERICA, N.A., (E.D. Tex. 2022).

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