Thomas v. Merchants Credit Association

CourtDistrict Court, W.D. Washington
DecidedMarch 25, 2020
Docket2:19-cv-01173
StatusUnknown

This text of Thomas v. Merchants Credit Association (Thomas v. Merchants Credit Association) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Thomas v. Merchants Credit Association, (W.D. Wash. 2020).

Opinion

1 2 3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 JOSH THOMAS, 8 Plaintiff, NO. C19-1173RSL 9 v. 10 ORDER GRANTING IN PART MERCHANTS CREDIT ASSOCIATION, DEFENDANT’S MOTION FOR 11 SUMMARY JUDGMENT Defendant. 12 13 14 15 This matter comes before the Court on “Defendant’s Motion for Summary Judgment,” 16 Dkt. # 13, and “Defendant Merchants Credit Association’s Motion[] for Sanctions Pursuant to 17 Rule 11,” Dkt. # 10. Plaintiff Josh Thomas, on behalf of himself and a class of similarly situated 18 persons, alleges that defendant Merchants Credit Association made false and defamatory 19 statements about him, violated the Washington Consumer Protection Act (“CPA”), and violated 20 the Fair Credit Reporting Act (“FCRA”) when it reported to credit reporting agencies that 21 plaintiff was delinquent on two medical debts. Plaintiff also alleges that defendant violated the 22 FCRA by failing to investigate the debts, failing to communicate with plaintiff, and failing to 23 correct errors once they were brought to its attention. Two days after the case management order 24 was issued, defendant moved for summary dismissal of all of plaintiff’s claims. 25 Summary judgment is appropriate when, viewing the facts in the light most favorable to 26 ORDER GRANTING IN PART DEFENDANT’S the nonmoving party, there is no genuine issue of material fact that would preclude the entry of 1 judgment as a matter of law. The party seeking summary dismissal of the case “bears the initial 2 responsibility of informing the district court of the basis for its motion” (Celotex Corp. v. 3 Catrett, 477 U.S. 317, 323 (1986)) and “citing to particular parts of materials in the record” that 4 show the absence of a genuine issue of material fact (Fed. R. Civ. P. 56(c)). Once the moving 5 party has satisfied its burden, it is entitled to summary judgment if the non-moving party fails to 6 designate “specific facts showing that there is a genuine issue for trial.” Celotex Corp., 477 U.S. 7 at 324. The Court will “view the evidence in the light most favorable to the nonmoving party . . . 8 and draw all reasonable inferences in that party’s favor.” Colony Cove Props., LLC v. City of 9 Carson, 888 F.3d 445, 450 (9th Cir. 2018). Although the Court must reserve for the trier of fact 10 genuine issues regarding credibility, the weight of the evidence, and legitimate inferences, the 11 “mere existence of a scintilla of evidence in support of the non-moving party’s position will be 12 insufficient” to avoid judgment. City of Pomona v. SQM N. Am. Corp., 750 F.3d 1036, 1049 (9th 13 Cir. 2014); Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 252 (1986). Factual disputes whose 14 resolution would not affect the outcome of the suit are irrelevant to the consideration of a motion 15 for summary judgment. S. Cal. Darts Ass’n v. Zaffina, 762 F.3d 921, 925 (9th Cir. 2014). In 16 other words, summary judgment should be granted where the nonmoving party fails to offer 17 evidence from which a reasonable fact finder could return a verdict in its favor. Singh v. Am. 18 Honda Fin. Corp., 925 F.3d 1053, 1071 (9th Cir. 2019). 19 Having reviewed the memoranda, declarations, and exhibits submitted by the parties and 20 taking the evidence in the light most favorable to plaintiff, the Court finds as follows: 21 BACKGROUND 22 In September 2017, plaintiff received medical care at Virginia Mason Medical Center 23 which resulted in two separate invoices. In March 2018, Virginia Mason assigned the unpaid 24 balance of both debts to defendant for collection. Defendant sent plaintiff two letters, one for 25 26 ORDER GRANTING IN PART DEFENDANT’S each debt, indicating that it was attempting to collect amounts owed, providing an opportunity to 1 dispute the debts, and requesting payment. Dkt. # 11-1 at 4 and 44. Plaintiff responded to the 2 notices, indicating that he had insurance and that Virginia Mason had either failed to submit the 3 claims for payment or had improperly submitted the claims. Plaintiff requested that defendant 4 submit claims to his insurer before contacting him again. Dkt. # 11-1 at 6-7 and 46. 5 On April 28th and May 10th, defendant sent two letters, both acknowledging plaintiff’s 6 dispute regarding the second, larger debt (Account # 5445833 with a principal amount of 7 $839.00). Dkt. # 11-1 at 18 and 50.1 Both letters included the name and address of the creditor 8 and a promise that the debt has been marked “disputed” if it were reported to a credit reporting 9 agency. The second letter enclosed a Virginia Mason Statement of Clinical Services related to 10 Merchants Account # 5425568, the smaller of the two debts: the statement and the letter to 11 which it is attached do not reference the same debt. Dkt. # 11-1 at 19. Following Merchants’ 12 lead, plaintiff sent two responsive letters, both regarding the larger of the two debts, Account 13 # 5445833. The first letter noted that defendant had not addressed the substance of his dispute: 14 he reiterated that Virginia Mason had either failed to submit a claim to his insurance carrier or 15 had improperly submitted the claim and that he would be willing to pay any unreimbursed 16 amounts once the claim was adjusted. Dkt. # 11-1 at 52 and 58. The second response, mailed a 17 few days later, keyed in on the Statement of Clinical Services defendant had forwarded with the 18 May 10th letter, arguing that Virginia Mason had written off the debt and therefore no amounts 19 were due. Plaintiff requested that defendant cease all collection efforts. Dkt. # 11-1 at 22. 20 Defendant claims that it reported both debts to Equifax as disputed on July 31, 2018. Dkt. 21 # 11 at ¶¶ 8 and 22. The evidence offered in support of these assertions consists of entries in 22 what appear to be Merchants’ internal computerized records stating “07-31-18 05:52PM *crpt 23 24 1 Contrary to the representations of Merchants’ compliance officer, Alexandra Sandoval, at Dkt. 25 # 11 at ¶ 6, the record contains no response to plaintiff’s dispute regarding the first, smaller debt (Merchants Account # 5425568 with a principal amount of $304.01). 26 ORDER GRANTING IN PART DEFENDANT’S account info disputed by consumer under FCRA . . . active bal $875 dt 1st delq 09262017” and 1 “07-31-18 05:56PM *crpt account info disputed by consumer under FCRA . . . active bal $319 2 dt 1st delq 09262017.” Dkt. # 11-1 at 66 and 26. While it is not entirely clear what information 3 was sent to Equifax, shortly thereafter plaintiff received an alert from a credit monitoring service 4 letting him know that Merchants had reported delinquent debts and that his credit rating had 5 dropped. Plaintiff asserts that he “saw no indications that Defendant Merchants was reporting the 6 debts as disputed.” Dkt. # 22 at ¶ 12. Plaintiff sent another letter to defendant on August 5, 2018, 7 indicating that the credit reports were erroneous, that Merchants had so far failed to address his 8 dispute on the merits, and that the alleged debt was fraudulent. Dkt. # 22-1 at 2. Plaintiff also 9 notified the credit reporting agencies that the debts were disputed. Dkt. # 22 at ¶ 14.

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Thomas v. Merchants Credit Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-v-merchants-credit-association-wawd-2020.