Saro v. Bank of America, NA

CourtDistrict Court, S.D. California
DecidedOctober 11, 2024
Docket3:22-cv-01798
StatusUnknown

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

Bluebook
Saro v. Bank of America, NA, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 Case No.: 22cv1798 DMS (DEB) NANCY SARO, an individual,

11 Plaintiff, ORDER GRANTING IN PART AND 12 v. DENYING IN PART DEFENDANT’S MOTION TO DISMISS 13 BANK OF AMERICA, NA; and DOES 1- 50, inclusive 14 Defendants. 15

16 17 This case comes before the Court on Defendant’s motion to dismiss Plaintiff’s First 18 Amended Complaint (“FAC”). Plaintiff filed an opposition to the motion, and Defendant 19 filed a reply. For the reasons discussed below, the motion is granted in part and denied 20 in part. 21 I. 22 BACKGROUND 23 Plaintiff Nancy Saro is the owner of the property located at 17601 Valle Verde 24 Road, Poway, CA 92064 (“the Property”). (FAC ¶ 7.) The Property is financed by three 25 loans totaling approximately $850,000.00, (id. ¶ 8), two of which are home equity lines 26 of credit (“HELOCs”) owned by Defendant Bank of America. (Id. ¶ 10.) 27 In February 2020, at the outset of the COVID-19 pandemic, Plaintiff entered into 28 a forbearance agreement with Defendant on her HELOCs. (Id. ¶ 13.) Thereafter, Plaintiff 1 requested a deferral on her past loan amounts with Defendant, which Defendant denied. 2 (Id. ¶ 15.) Plaintiff then began the process of modifying her loan with Defendant. (Id. ¶ 3 16.) Plaintiff alleges that during this process she submitted information to Defendant, but 4 Defendant claimed it lost Plaintiff’s application. Plaintiff also alleges Defendant denied 5 her application. (Id. ¶ 18.) Plaintiff alleges this happened twice during the loan 6 modification process. (Id. ¶ 19-20.) Plaintiff further alleges that after Defendant denied 7 Plaintiff’s second application it began to harass her “over the phone” about one of her 8 HELOCs. (Id. ¶ 21.) 9 Plaintiff then decided to apply for a reverse mortgage to pay off her loans with 10 Defendant. (Id. ¶ 22.) Plaintiff alleges she was working with broker Summit Lending, 11 which needed certain information from Defendant to proceed with the reverse mortgage, 12 but Defendant failed to provide that information. (Id. ¶ 23.) 13 Plaintiff alleges that although Defendant knew Plaintiff was attempting to secure a 14 reverse mortgage, it began foreclosure proceedings against the Property. (Id. ¶ 30.) 15 Plaintiff alleges she was unable to secure the reverse mortgage due to Defendant’s failure 16 to provide the broker with the necessary information. (Id. ¶ 36.) 17 As a result of these events, Plaintiff filed the present case against Defendant 18 alleging claims for interference with prospective economic advantage, elder financial 19 abuse, breach of the covenant of good faith and fair dealing, intentional misrepresentation, 20 negligent misrepresentation, and violation of California Business and Professions Code § 21 17200, et seq. After some initial motions, the parties requested a stay of the case so they 22 could pursue settlement, which the Court granted. After four extensions and no 23 settlement, the stay was lifted and Defendant filed a motion to dismiss. Plaintiff thereafter 24 filed the FAC, and Defendant filed the present motion. 25 II. 26 DISCUSSION 27 Defendant moves to dismiss Plaintiff’s FAC in its entirety. In response, Plaintiff 28 requests leave to amend her claims for bad faith, intentional misrepresentation, negligent 1 misrepresentation, and her claim under California Business and Professions Code § 2 17200. Plaintiff’s other two claims are discussed below. 3 A. Legal Standard 4 In Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 5 U.S. 544 (2007), the Supreme Court established a more stringent standard of review for 6 12(b)(6) motions. To survive a motion to dismiss under this standard, “a complaint must 7 contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible 8 on its face.’” Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 570). “A claim has facial 9 plausibility when the plaintiff pleads factual content that allows the court to draw the 10 reasonable inference that the defendant is liable for the misconduct alleged.” Id. (citing 11 Twombly, 550 U.S. at 556). 12 “Determining whether a complaint states a plausible claim for relief will ... be a 13 context-specific task that requires the reviewing court to draw on its judicial experience 14 and common sense.” Id. at 679 (citing Iqbal v. Hasty, 490 F.3d 143, 157-58 (2d Cir. 2007)). 15 In Iqbal, the Court began this task “by identifying the allegations in the complaint that are 16 not entitled to the assumption of truth.” Id. at 680. It then considered “the factual 17 allegations in respondent’s complaint to determine if they plausibly suggest an entitlement 18 to relief.” Id. at 681. 19 B. Interference with Prospective Economic Advantage 20 Here, the first disputed claim is Plaintiff’s claim for intentional interference with 21 prospective economic advantage. 22 In order to prove a claim for intentional interference with prospective economic advantage, a plaintiff has the burden of proving five elements: (1) 23 an economic relationship between plaintiff and a third party, with the 24 probability of future economic benefit to the plaintiff; (2) defendant’s knowledge of the relationship; (3) an intentional act by the defendant, 25 designed to disrupt the relationship; (4) actual disruption of the relationship; 26 and (5) economic harm to the plaintiff proximately caused by the defendant’s wrongful act, including an intentional act by the defendant that is designed to 27 disrupt the relationship between the plaintiff and a third party. 28 1 Edwards v. Arthur Andersen LLP, 44 Cal. 4 937, 944 (2008) (citing Korea Supply Co. v. 2 Lockheed Martin Corp., 29 Cal. 4th 1134, 1153-54 (2003)). In addition, Plaintiff must 3 “plead and prove as part of its case-in-chief that the defendant’s conduct was ‘wrongful by 4 some legal measure other than the fact of interference itself.’” Korea Supply, 29 Cal. 4th 5 at 1153 (quoting Della Penna v. Toyota Motor Sales, U.S.A., Inc., 11 Cal. 4th 376, 393 6 (1995)). 7 Here, Defendant argues Plaintiff has failed to allege sufficient facts to support the 8 elements of (1) an intentional act designed to disrupt Plaintiff’s relationship with a third 9 party, and (2) injury. On the first of these elements, Plaintiff alleges Defendant “refused 10 to give Summit Lending access to Plaintiff’s records multiple times after Plaintiff supplied 11 Defendant with multiple signed formal waivers.” (FAC ¶ 42.) Defendant responds to this 12 allegation by arguing that it declined to provide Summit Lending access to Plaintiff’s 13 information because it was following its own consumer protection policies, which are 14 required by federal law. This argument explains why Defendant failed to provide 15 Plaintiff’s information to Summit Lending, but it does not show that Plaintiff has failed to 16 allege sufficient facts to support this claim. Accordingly, this argument does not warrant 17 dismissal at this stage of the proceedings. 18 On the injury element, Defendant argues Plaintiff’s alleged injury, namely, her 19 inability to obtain a jumbo reverse mortgage, is speculative, and therefore insufficient to 20 support this claim. Defendant cites two cases in support of this argument, neither of which 21 is persuasive. First, Hart v. Select Portfolio Servicing, Inc., No. 2:22-cv-03399-FLA 22 (MRWx), 2023 WL 7107277 (C.D. Cal. Sept. 27, 2023), was an order on summary 23 judgment, not a motion to dismiss. The facts of Hart are also distinguishable from the facts 24 of this case. In Hart the court noted the plaintiff failed to “present any evidence 25 demonstrating he sought or applied for” a refinance or modification of his loan. Id. at *5.

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Related

Iqbal v. Hasty
490 F.3d 143 (Second Circuit, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Consumer Solutions Reo, LLC v. Hillery
658 F. Supp. 2d 1002 (N.D. California, 2009)
Davenport v. Litton Loan Servicing, LP
725 F. Supp. 2d 862 (N.D. California, 2010)
Della Penna v. Toyota Motor Sales, USA, Inc.
902 P.2d 740 (California Supreme Court, 1995)
Korea Supply Co. v. Lockheed Martin Corp.
63 P.3d 937 (California Supreme Court, 2003)
Insurance Co. v. Ritchie
5 U.S. 541 (Supreme Court, 1866)

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Bluebook (online)
Saro v. Bank of America, NA, Counsel Stack Legal Research, https://law.counselstack.com/opinion/saro-v-bank-of-america-na-casd-2024.