Stephenson v. Navy Federal Credit Union

CourtDistrict Court, S.D. California
DecidedSeptember 20, 2024
Docket3:23-cv-01851
StatusUnknown

This text of Stephenson v. Navy Federal Credit Union (Stephenson v. Navy Federal Credit Union) 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
Stephenson v. Navy Federal Credit Union, (S.D. Cal. 2024).

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 SOUTHERN DISTRICT OF CALIFORNIA 7 8 JEFFREY STEPHENSON, Case No.: 23-cv-1851-WQH-KSC individually, on behalf of himself 9 and all others similarly situated, ORDER 10 Plaintiff, 11 v. 12 NAVY FEDERAL CREDIT 13 UNION, Defendant. 14 15 HAYES, Judge: 16 The matter before the Court is the Motion to Dismiss First Amended Complaint 17 (“Motion to Dismiss”) filed by Defendant Navy Federal Credit Union (“Defendant” or 18 “NFCU”). (ECF No. 19.) 19 I. BACKGROUND 20 On October 10, 2023, Plaintiff Jeffrey Stephenson (“Plaintiff”) initiated this action 21 by filing a Class Action Complaint against Defendant, asserting claims on behalf of himself 22 and class members similarly situated relating to unauthorized charges on their accounts 23 and denial of reimbursement. (ECF No. 1.) 24 On January 22, 2024, Plaintiff filed the First Amended Complaint (“FAC”), the 25 operative pleading, again asserting claims on behalf of himself and class members similarly 26 situated relating to unauthorized charges on their accounts and denial of reimbursement. 27 (ECF No. 17, FAC.) 28 1 On February 21, 2024, Defendant filed the Motion to Dismiss First Amended 2 Complaint. (ECF No. 19.) On March 22, 2024, Plaintiff filed a Response in opposition to 3 the Motion to Dismiss First Amended Complaint. (ECF No. 22.) On April 5, 2024, 4 Defendant filed a Reply in support of the Motion to Dismiss First Amended Complaint. 5 (ECF No. 24.) 6 II. ALLEGATIONS IN THE FIRST AMENDED COMPLAINT 7 Since roughly April 2020, Plaintiff and his seventeen-year-old son have maintained 8 a joint checking account with Defendant, which is “a national credit card union” that is 9 “engaged in the business of providing retail banking services to consumers,” including by 10 issuing debit cards “for use by its customers in conjunction with their checking accounts.” 11 (FAC ¶ 15.) 12 On or about February 22, 2023, Plaintiff learned that his NFCU debit card had been 13 stolen out of his son’s backpack. Plaintiff and his son discovered the card had gone missing 14 after they “notic[ed] several unauthorized transactions occurred on their account.” Id. ¶ 23. 15 On February 23, 2023, Plaintiff alerted NFCU that the debit card had been stolen and 16 submitted a fraud claim that included “substantial factual proof identifying” “$991.98 in 17 fraudulent purchases.” Id. ¶¶ 2, 24. “For example, Plaintiff disclosed that the purchase 18 history since the debit card was acquired over 400+ purchases ago demonstrates that there 19 were no purchases made at Walmart, yet 11 of the unauthorized transactions occurred at 20 Walmart all within the short period of 14 days.” Id. ¶ 25. 21 On February 24, 2023, one day after Plaintiff had submitted the fraud claim, “NFCU 22 sent a letter informing Plaintiff of its ‘final determination’ of the fraud claim in which it 23 concluded that ‘no error has occurred’” (the “First Letter”). Id. ¶ 26. The First Letter stated 24 that “Our investigation was based on a review of your account activity, including, but not 25 limited to: transaction details, account history, and/or discrepancies between the fraud 26 claim and your account.” Id. (citing ECF No. 17-1, Exh. A, February 24, 2023, Letter). 27 Plaintiff submitted additional information using NFCU’s website and included “written 28 responses to seven questions posed by NFCU.” Id. ¶ 27. Plaintiff appealed NFCU’s 1 decision in the First Letter. Plaintiff’s appeal identified charges with many merchants that 2 Plaintiff had never purchased from and pointed out Plaintiff’s account history to show 3 “Plaintiff had only previously made low-dollar purchases with his debit card, unlike many 4 of the fraudulent charges that were over a $100.” Id. ¶ 28. In the appeal, Plaintiff also filed 5 a police report, “reporting the stolen card and fraudulent charges,” and provided NFCU 6 with the report number. Id. ¶ 29. 7 On March 10, 2023, NFCU sent another letter to Plaintiff “reporting the findings of 8 its second review of his fraud claim” (the “Second Letter”). Id. ¶ 30. NFCU denied 9 Plaintiff’s claim, stating, “After carefully reviewing the information you provided, we have 10 concluded that no error occurred. Therefore, the original decision to deny the claim stands. 11 You are responsible for the full amount of the claim, $991.98.” Id. (citing ECF No. 17-2, 12 Exh. B, March 10, 2023, Letter). 13 On March 26, 2023, Plaintiff requested more information concerning NFCU’s denial 14 using NFCU’s website. On March 30, 2023, NFCU responded to Plaintiff and stated that 15 “In order to receive the documents requested, you will need to file a report with your local 16 police department. Your local police can then subpoena our records.” Id. (citing ECF No. 17 17–3, Exh. C, March 30, 2023, Online Response). 18 On March 31, 2023, Plaintiff met with an NFCU branch manager to acquire more 19 information about the denials, “but no one could offer him any further information about 20 why his fraud claim was denied.” Id. ¶ 32. 21 On April 3, 2023, Plaintiff submitted a claim to the Consumer Financial Protection 22 Bureau (“CFPB”). On June 2, 2023, NFCU responded to the CFPB claim, “affirming its 23 conclusion that Plaintiff’s fraud claim was denied,” “again failing to offer any justification 24 in support of its determination,” and reiterating that it “found the claim to be unsupported.” 25 Id. ¶ 34. NFCU stated: “Based on the facts of our investigation, we determined that the 26 claim remains denied. All account owners remain responsible for the activity that was 27 conducted on the account.” Id. (citing ECF No. 17-4, Exh. D, CFPB Complaint Status 28 Report). CFPB closed Plaintiff’s complaint based on NFCU’s response. 1 Plaintiff submitted a complaint to the Better Business Bureau (“BBB”), to which 2 NFCU directly responded by confirming its first and second review decisions and making 3 the same response that it “found the claim to be unsupported” (the “Third Letter”). Id. ¶ 36. 4 NFCU stated: “Based on the facts of our investigation, we determined that the claim 5 remains denied. All account owners remain responsible for the activity that was conducted 6 on the account.” Id. (citing ECF No. 17-5, Exh. E, June 2, 2023, Letter). 7 “To date, Plaintiff has not been refunded any of the $991.98 in fraudulent 8 purchases.” Id. ¶ 37. 9 The Navy Federal Credit Union Debit Card Disclosure (the “Agreement”) states: 10 Cardholder Liability for Unauthorized Transactions: NOTIFY US AT ONCE if you believe that your D[ebit] C[ard] or personal identification 11 number (PIN) has been lost, stolen, or used (or may be used) without your 12 authority. The best way to minimize your possible losses is to contact us as soon as possible by calling us at the number above or, if you have Navy 13 Federal Online Banking, by using the Report Fraud feature. You may also 14 notify us in person at any branch or in writing using the address above.

15 Timely Notice of Missing D[ebit] C[ard]: If you notify us within 2 business 16 days after you learn of the loss or theft of your D[ebit] C[ard] or PIN, your losses will be no more than $50 if someone used your D[ebit] C[ard] or PIN 17 without your permission. 18 Id. ¶ 54 (quoting ECF No. 17–6, Exh. F, Agreement ¶ 14). In the Agreement, “NFCU also 19 promises that NFCU will investigate ‘unauthorized transactions’ in accordance with its 20 ‘Billing Error Resolution’ process.” Id. ¶ 57. NFCU promises “zero liability” for 21 transactions that it “confirms” are fraudulent, stating the following in the Agreement: 22 Navy Federal’s Zero Liability Policy for Fraud: In addition to the liability 23 limits above, if you notify us of suspected fraud within 60 days of the 24 statement date on which the fraudulent transactions first appear, we will not hold you responsible for confirmed fraudulent transactions.

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Bluebook (online)
Stephenson v. Navy Federal Credit Union, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephenson-v-navy-federal-credit-union-casd-2024.