Pfeiffer v. Spellings

CourtDistrict Court, District of Columbia
DecidedOctober 5, 2009
DocketCivil Action No. 2007-0522
StatusPublished

This text of Pfeiffer v. Spellings (Pfeiffer v. Spellings) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pfeiffer v. Spellings, (D.D.C. 2009).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

_____________________________ ) BRENDA KAY PFEIFFER, ) ) Plaintiff, ) ) ) Civ. No. 07–522 (EGS) v. ) ) ARNE DUNCAN,1 Secretary ) of Education, et. al., ) ) Defendants. ) _____________________________ )

MEMORANDUM OPINION

Student loan borrower Brenda Kay Pfeiffer has brought this

breach of contract action against the U.S. Secretary of

Education, the Department of Education, and the United States

(collectively “DOE” or “defendants”). Plaintiff alleges that

defendants violated the terms of the promissory note governing

her student loan repayment plan, and has moved for partial

summary judgment on the issue of liability. Defendants have also

filed a motion for summary judgment. The question before the

Court is whether the promissory note executed by plaintiff

contractually authorizes defendants to capitalize interest that

accrued during the period between defendants’ receipt of

1 The complaint, filed on March 19, 2007, named as defendant Margaret Spellings, in her official capacity as U.S. Secretary of Education. Arne Duncan was sworn in as Secretary of Education on January 20, 2009 and is therefore substituted in his official capacity for Ms. Spellings as a defendant in this case pursuant to Fed. R. Civ. P. 25(d). plaintiff’s June scheduled payment and June 30 – the date on

which DOE annually capitalizes accrued interest – for those years

when plaintiff’s loan was in a “negative-amortization condition”

under the Income Contingency Repayment Plan (“ICRP”) in which she

participated. Upon consideration of the motions, responses and

replies thereto, the applicable law, the entire record, and for

the reasons stated below, the Court GRANTS IN PART AND DENIES IN

PART both parties’ motions.

I. Background

A. DOE’s Direct Loan Program

DOE lends money to students pursuing post-secondary

education through the William D. Ford Direct Loan Program (the

“Direct Loan Program”). Borrowers participating in the Direct

Loan Program are given a number of repayment plans from which to

choose, see 34 C.F.R. § 685.208; Defs.’ Mot. at 4 n.2, one of

which is the ICRP. Under the ICRP, a borrower’s scheduled

monthly payment is determined by a formula based on “adjusted

annual income, family size and the principal balance of the

loan.” Pl.’s Statement of Undisputed Material Facts (“Pl.’s

Statement”) ¶ 8; see 34 C.F.R. § 685.209(a) (explaining

calculation of borrower’s repayment amount under ICRP). Because

the monthly scheduled payments of borrowers participating in the

ICRP are based primarily on their income rather than on the

amount of their loan, the scheduled payment can sometimes be an

2 amount less than the interest accruing on their loans each month.

Pl.’s Statement ¶ 10; Defs.’ Mot. at 7. DOE designates these

loans as being in a negative-amortization condition. See Pl.’s

Mot. at 2; Defs.’ Statement of Material Facts as to Which There

Are No Genuine Issues to Be Tried (“Defs.’ Statement”) ¶ 21.

Individuals who obtain student loans from DOE pursuant to

the Direct Loan Program execute identical or substantially

identical form promissory notes. Pl.’s Statement ¶¶ 1-2. The

promissory note contains “the terms and conditions of the loan,

including how and when the loan must be repaid.” Pl.’s Statement

¶ 2 (internal citations and quotation marks omitted).

When a student borrower’s loan enters repayment, DOE assigns

each borrower a monthly “payment due date” of the 7th, 14th,

21st, or 28th of each month.2 Pl.’s Statement ¶ 6; Tr. of Nov.

14, 2008 Mot. Hr’g (“Tr.”) at 45, 56. When the agency receives a

payment on a student loan, it applies the payment “first to any

accrued charges and collection costs, then to any outstanding

interest, and then to outstanding principal.” 34 C.F.R. §

685.211(a)(1). On each monthly due date, DOE bills the borrower

for the interest that has accrued as of his or her payment date.

Pl.’s Mot. at 2. Interest that accrues after a borrower’s

2 At the hearing held on November 14, 2008, counsel for defendants initially stated that borrowers actually pick their due dates. Tr. at 19. Counsel later clarified that the agency assigns a payment due date to the borrower, but the borrower has the ability to change that date. Tr. at 62.

3 monthly due date is not billed until the borrower’s next monthly

due date the following month. Pl.’s Mot. at 2.

B. DOE’s Capitalization of Interest

Borrowers participating in the ICRP who are in a negative-

amortization condition may be subject to the capitalization of

certain interest that accrues on their loans. As defined by 34

C.F.R. § 685.202(b)(1), capitalization is the process of

increasing the principal balance of a loan by “add[ing] unpaid

accrued interest to the borrower’s unpaid principal balance.”

DOE’s form promissory notes describe the agency’s practice of

capitalizing interest as follows:

Interest. Except for interest [DOE] does not charge me during an in-school, grace or deferment period, I agree to pay interest on the principal amount of my Direct Consolidation Loan from the date of disbursement until the loan is paid in full or discharged. [DOE] may add interest that accrues but is not paid when due to the unpaid principal balance of this loan, as provided under the Act. This is called capitalization.

Pl.’s Mot. at Ex. 6 (form promissory note used in 2001); Defs.’

Mot. App. at 27 (same).

DOE regulations also address the agency’s authority to

capitalize interest, but the regulatory language differs somewhat

from the language contained in the form promissory notes.

Specifically, 34 C.F.R. § 685.202(b) states that “the Secretary

[of Education] annually capitalizes unpaid interest when the

borrower is paying under the [ICRP] and the borrower’s scheduled

4 payments do not cover the interest that has accrued on the loan.”

Id. § 685.202(b)(4).

The standard form promissory notes executed by borrowers

also contain a section relating to governing law. See Pl.’s Mot.

at Ex. 3. That provision of the promissory note states that

[t]he terms of this [promissory note] will be interpreted in accordance with the Higher Education Act of 1965, as amended (20 U.S.C. 1070 et seq.), the U.S. Department of Education’s . . . regulations, as they may be amended in accordance with their effective date, and other applicable federal laws and regulations (collectively referred to as the “Act”).

Id.; Defs.’ Mot. App. at 30.

Since at least March 19, 2001, DOE has been capitalizing

interest accrued on loans in a negative-amortization condition

not paid as of June 30 each year, a date that is not specified in

the regulations but is chosen by the agency for administrative

reasons. See Pl’s Statement ¶ 11; Tr. at 37, 44-45. These

interest-capitalization procedures are based upon a borrower’s

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