Smith v. Padgett Law Group

CourtDistrict Court, W.D. Tennessee
DecidedJune 26, 2025
Docket2:25-cv-02119
StatusUnknown

This text of Smith v. Padgett Law Group (Smith v. Padgett Law Group) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. Padgett Law Group, (W.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

ARLISHIA SMITH, ) ) Plaintiff, ) ) No. 2:25-cv-02119-TLP-tmp v. ) ) PADGETT LAW GROUP and PLANET ) HOME LENDING LLC, ) ) Defendants. )

ORDER ADOPTING REPORT AND RECOMMENDATION

In February 2025, pro se Plaintiff Arlishia Smith (“Plaintiff”) sued Padgett Law Group and Planet Home Lending LLC (collectively “Defendants”) over the nonjudicial foreclosure of her residential home.1 (ECF No. 1.) Under Administrative Order No. 2013-05, the Court referred this case to Chief Magistrate Judge Tu M. Pham (“Judge Pham”) for management of all pretrial matters.

1 Plaintiff asserts that her case here is a “removal… from the Bankruptcy Court of Tennessee.” (ECF No. 1 at PageID 1.) In making this claim, Plaintiff references her case in the Bankruptcy Court for the Western District of Tennessee for Chapter 13 protections and cites 28 U.S.C. § 1452. See In re Arlishia R. Smith, No. 24-bk-26224 (Bankr. W.D. Tenn.). But Judge Pham correctly decided that such removal would be procedurally improper. Indeed, “[r]emoval from a bankruptcy court to a district court is, generally, not proper because bankruptcy court is a ‘unit of the district court.’” Lee v. United States, No. 1:24-CV-205, 2024 WL 4116458, at *2 (W.D. Mich. Sept. 9, 2024) (quoting In re Conco, Inc., 855 F.3d 703, 709 (6th Cir. 2017)). Lastly, as Judge Pham explains, Plaintiff voluntarily dismissed her bankruptcy case in March 2025. In re Arlishia R. Smith, No. 24-bk-26224 (Bankr. W.D, Tenn Mar. 5, 2025) (ECF No. 30). Judge Pham therefore correctly construes this case as a new, independent action, rather than as a removal of her bankruptcy action. (ECF No. 21 PageID 160–61.) Because no party objected and for the reasons Judge Pham explained, the Court follows suit. Defendants now move to dismiss Plaintiff’s Complaint and they move to strike the Amended Complaint. (ECF Nos. 14, 15, 20.) Judge Pham reviewed these motions, and he entered a Report and Recommendation (“R&R”) recommending that the Court grant the motions to dismiss and deny the motion to strike as moot. (ECF No. 21.)

Neither side objects to Judge Pham’s R&R. So the Court reviews the R&R for clear error. As explained below, the Court finds no error in Judge Pham’s analysis and ADOPTS the R&R. As a result, the Court GRANTS Defendants’ motions to dismiss, DENIES as MOOT Defendants’ motion to strike, and DISMISSES the case WITH PREJUDICE. BACKGROUND In Feburary 2025, Plaintiff sued here and alleged that Defendants violated various statutes, the Due Process and Takings Clauses of the Fifth Amendment, and the First Amendment when they conducted the nonjudicial foreclosure of her property. (ECF No. 1 at PageID 2.) Judge Pham notes that the Complaint is hard to follow and sparse, and it cites statutes of questionable relevance and makes conclusory claims. (ECF No. 21 at PageID 160–

61.) For example, Plaintiff alleges that Defendants’ “actions, including the dual collateralization and failure to account for monetization of the promissory note, constitute violations of these protections.” (ECF No. 1 at PageID 2.) In March 2025, both Defendants moved to dismiss under Federal Rules of Civil Procedure 12(b)(6). (ECF Nos. 14, 15.) Plaintiff failed to respond timely to the motions and so Judge Pham entered an Order to Show Cause. (ECF No. 17.) Following that Order, Plaintiff, without leave of Court, amended her Complaint with a document styled “Amended Petition to Strike Unlawful Attorney Actions and Claims for Damages under Federal Law and Constitutional Authority.” (ECF No. 19.) With this “Amended Complaint,” Plaintiff added claims that Defendants violated several constitutional amendments, including the Fourth, Ninth, and Tenth Amendments. (Id. at PageID 149.) She also added a Fair Debt Collections Practices Act claim under 15 U.S.C. § 1692c(a). (Id. at PageID 150.) Plaintiff then responded in opposition to Defendants’ motions to dismiss. (ECF No. 18.) And Defendants now move to

strike the Amended Complaint, arguing it is redundant and procedurally improper. (ECF No. 20.) THE R&R After recounting the factual and procedural history, Judge Pham analyzed the relevant standard of review. (ECF No. 21.) Judge Pham then reviewed Defendants’ motions to dismiss and assessed whether Plaintiff stated claims for which relief may be granted. (Id.) In the interest of justice and completeness, Judge Pham reviewed and analyzed both Plaintiff’s Complaint and Amended Complaint. (Id.) In the end, Judge Pham found that Plaintiff failed to provide an adequate factual basis for any of her claims. (Id.) What is more, Judge Pham found that Plaintiff’s constitutional claims should fail because she did not allege state action by Defendants.

(Id.) The Court next recites the relevant legal standards and then explains why it adopts the R&R. LEGAL STANDARD When deciding whether a complaint states a claim on which relief can be granted, courts apply the standard of Federal Rules of Civil Procedure 8 and 12(b)(6) as explained by the Supreme Court in Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). Fed. R. Civ. P. 12(b)(6). “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678 (quoting Twombly, 550 U.S. at 570). In other words, “[a] 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. A court must “construe the complaint in the light most favorable to the plaintiff, accept its allegations as true, and draw all reasonable inferences in favor of the plaintiff.” Wamer v.

Univ. of Toledo, 27 F.4th 461, 466 (6th Cir. 2022), cert. denied, 143 S. Ct. 444 (2022) (citation omitted). But courts ruling on a motion to dismiss need not accept “legal conclusions or unwarranted factual inferences.” Moderwell v. Cuyahoga Cnty., 997 F.3d 653, 659 (6th Cir. 2021) (quoting Jackson v. Prof’l Radiology Inc., 864 F.3d 463, 466 (6th Cir. 2017)). Instead, the “complaint must contain direct or inferential allegations respecting all the material elements under some viable legal theory.” Arsan v. Keller, 784 F. App’x 900, 909 (6th Cir. 2019) (quoting Commercial Money Ctr. v. Ill. Union Ins., 508 F.3d 327, 336 (6th Cir. 2007)). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.”2 Iqbal, 556 U.S. at 678 (citing Twombly, 550 U.S. at 555). Courts must “liberally construe[]” pleadings filed by pro se plaintiffs and hold them to

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Bluebook (online)
Smith v. Padgett Law Group, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-padgett-law-group-tnwd-2025.