Thomas v. Dover Federal Credit Union

Superior Court of Delaware·Decided February 27, 2026·No. K24C-12-009 RLG·Published

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

AMY THOMAS, on behalf of herself ) and all others similarly situated, )

) C.A. No. K24C-12-009 RLG Plaintiff, )

)

DOVER FEDERAL CREDIT ) UNION, )

)

Defendant. )

Submitted: November 19, 2025 Decided: February 27, 2026

OPINION

Upon Defendant’s Motion to Dismiss – GRANTED

Lisa M. La Fornara, Esquire (argued) (PHV), Cohen & Malad, LLP, Indianapolis, Indiana. J. Gerard Stranch, IV, Esquire (PHV), Stranch, Jennings & Garvey, PLLC, Nashville, Tennessee. Derrick B. Farrell, Esquire; Lesley E. Weaver, Esquire; Matthew L. Miller, Esquire; and Robert B. Lackey, Esquire, Bleichmar Fonti & Auld LLP, Wilmington, Delaware. Attorneys for Plaintiff.1

Scott R. Sinson (PHV), Esquire and Kevin A. Ameriks, Esquire (PHV), Gordon Rees Scully Mansukhani, Chicago, Illinois. Krista M. Reale, Esquire, Margolis Edelstein, Wilmington, Delaware. Attorneys for Defendant.

GREEN-STREETT, J. 1 The listed attorneys at Bleichmar Fonti & Auld LLP represented Plaintiff at the time of the October 24, 2025 hearing. On February 18, 2026, while the Court’s decision was still pending on Defendant’s Motion to Dismiss, local counsel for Plaintiff was substituted. Plaintiff is now represented by Peter B. Andrews, Esquire and David M. Sborz of Andrews and Springer LLC. Ms. La Fornara and Mr. Stranch, formerly entered pro hac vice, remain. See D.I. 36 (Feb. 18, 2026).

I. Introduction A member of a credit union attempted to make a payment to a merchant without sufficient funds in her account to cover the transaction. The credit union rejected the transaction and charged the member a fee for insufficient funds. The merchant resubmitted the transaction and the credit union rejected the transaction a second time, resulting in another fee for insufficient funds. The member brought the instant litigation, alleging the second fee breached her membership agreement with the credit union. As the second fee did not breach the membership agreement, the credit union’s Motion to Dismiss is GRANTED. II. Factual and Procedural Background A. The underlying transaction In 2024, Plaintiff Amy Thomas maintained a checking account as a member of Defendant Dover Federal Credit Union (“Dover”).2 On October 4, 2024, Ms. Thomas attempted to make a payment from that checking account for $1,272.00.3 Dover rejected that payment because of insufficient funds in Ms. Thomas’s checking account, and charged her a $30.00 fee.4 On October 9, 2024, the merchant resubmitted the payment request, and Dover attempted to process the payment a

2 Compl. at 11.

3 Id.

4 Id.

second time.5 Dover rejected the transaction again for insufficient funds, and charged Ms. Thomas a second $30.00 fee for insufficient funds.6 In total, Dover charged Ms. Thomas $60.00 in fees for the failed transactions.7 B. The instant litigation and the membership agreements Ms. Thomas filed her Complaint on December 6, 2024, alleging breach of contract; breach of the duty of good faith and fair dealing; unjust enrichment; and a violation of the Delaware Uniform Deceptive Trade Practices Act.8 Ms. Thomas raised these allegations individually, as well as by class action under Superior Court Civil Rule 23.9 In support of her allegations, Ms. Thomas attached a membership agreement issued by Dover dated 2016 (the “2016 Agreement”)10 and Dover’s fee schedule that noted an effective date of September 1, 2024 (the “2024 Fee Schedule”).11

5 Id.

6 Id.

7 Id.

8 Id. at 17-20.

9 Id. at 13.

10 Compl. Ex. A (the “2016 Agreement”).

11 Compl. Ex. B (the “2024 Fee Schedule”).

The 2016 Agreement informs members, “[i]f a check, item[,] or transaction is presented without sufficient funds in your account to pay it, we may, at our discretion, pay the item (creating an overdraft) or return the item for insufficient funds (NSF).”12 The 2024 Fee Schedule identifies a fee for “ACH NSF per Item/Paid or Returned” totaling $30.00.13 The 2024 Fee Schedule also lists a fee for “NSF Bill Pay per item” of $30.00.14 On February 5, 2025, Dover filed the instant Motion to Dismiss under Superior Court Civil Rule 12(b)(6) for failure to state a claim and 12(b)(1) for lack of subject matter jurisdiction.15 In support of its Motion, Dover attached a different membership agreement dated 2019 (the “2019 Agreement”)16 and a different fee schedule effective May 7, 2021 (the “2021 Fee Schedule”).17 Although the disparate fee schedules appear largely consistent, the two membership agreements (collectively, the “Membership Agreements”) are materially different. Critically, the

12 The 2016 Agreement at 3.

13 The 2024 Fee Schedule at 1.

14 Id. at 5.

15 Mot. to Dismiss at 1.

16 Mot. to Dismiss Ex. A (the “2019 Agreement”).

17 Mot. to Dismiss Ex. B (the “2021 Fee Schedule”).

2019 Agreement contains a paragraph after the heading “Nonsufficient funds (NSF fees),” outlining that:

If an item drafted by you (such as a check) or a transaction you set up (such as a preauthorized transfer) is presented for payment in an amount that is more than the amount of money available in your account, and we decide not to pay the item or transaction, you agree that we can charge you an NSF fee for returning the payment. Be aware that such an item or payment may be presented multiple times and that we do not monitor or control the number of times a transaction is presented for payment. You agree that we may charge you an NSF fee each time a payment is presented if the amount of money available in your account is not sufficient to cover the payment, regardless of the number of times the payment is presented.18

Dover’s Motion focused on the validity of Ms. Thomas’s claims under the 2019 Agreement.

Ms. Thomas filed her Response to Dover’s Motion to Dismiss on March 7, 2025. At that time, Ms. Thomas voluntarily dismissed her claim under the Delaware Uniform Deceptive Trade Practices Act.19 Aside from disputing Dover’s interpretation of the two agreements generally, Ms. Thomas also asserted, “Dover has not authenticated the effective dates of the purported contract documents it seeks

18 The 2019 Agreement at 2.

19 Resp. at 2 n.2.

to introduce.”20 Accordingly, Ms. Thomas contended a factual dispute existed over which agreement should control the Court’s analysis.21 Dover responded by providing an affidavit from its authorized agent, averring the 2019 Agreement took effect before Ms. Thomas’s failed transaction and Dover’s imposition of the two fees for insufficient funds (the “Affidavit”).22 The parties each submitted supplemental filings providing additional decisional law from various jurisdictions in support of their respective positions.23 After a continuance permitting the parties to engage in settlement negotiations,24 the Court held oral argument on October 24, 2025.25 III. Standard of Review Under Superior Court Civil Rule 12(b)(6), this Court views the Complaint “in [a] light most favorable to the nonmoving party, accepting as true its well-pled allegations and drawing all reasonable inferences that logically flow from those

20 Resp. at 4.

21 Id. at 9-10.

22 Def.’s Reply Ex. A. See D.I. 11 (Mar. 18, 2025).

23 Pl.’s Suppl. Filing, D.I. 29 (Oct. 16, 2025); Def.’s Suppl. Filing, D.I. 31 (Oct. 22, 2025).

24 See D.I. 24 (Jun. 24, 2025).

25 Tr. of Oral Arg., D.I. 34 (Nov. 19, 2025) (hereinafter, “Tr. at __”).

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Thomas v. Dover Federal Credit Union, (Del. Ct. App. 2026).

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