TMX Finance LLC v. Spicher

CourtDistrict Court, M.D. Pennsylvania
DecidedJanuary 16, 2025
Docket1:24-cv-02093
StatusUnknown

This text of TMX Finance LLC v. Spicher (TMX Finance LLC v. Spicher) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
TMX Finance LLC v. Spicher, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA TMX FINANCE LLC and : Civil No. 1:24-CV-02093 TITLEMAX FUNDING, INC., : : Plaintiffs, : : v. : : WENDY SPICHER, in her official : capacity as Secretary of the : Pennsylvania Department of Banking : and Securities, : : Defendant. : Judge Jennifer P. Wilson MEMORANDUM Plaintiffs and their affiliates filed this and other federal lawsuits throughout the country in an effort to enjoin a state civil enforcement action initiated by the Pennsylvania Department of Banking and Securities (“Department”). The Department accuses Plaintiffs and their affiliates of issuing usurious loans to Pennsylvania consumers in violation of Pennsylvania’s statutory usury laws. Currently submitted for the court’s consideration is the motion to dismiss submitted by Defendant, Wendy Spicher, the Secretary of the Department (“Defendant”). Defendant contends that this court must abstain from exercising jurisdiction over this matter pursuant to Younger v. Harris, 401 U.S. 37 (1971), and its progeny. For the reasons set forth herein, the Younger abstention doctrine necessitates this action’s dismissal. Accordingly, the court will grant the Defendant’s motion. BACKGROUND This lawsuit is another episode in a years-long dispute between Plaintiffs

and the Department over alleged usury. Plaintiff TMX Finance LLC is the parent company of Plaintiff TitleMax Funding, Inc. and certain “TitleMax entities” that offer loans secured by liens in borrowers’ automobiles. (Doc. 1 ¶ 20; Compl. at 2, TitleMax of Delaware, Inc. v. Spicher, No. 1:24-CV-02224 (M.D. Pa. Aug. 13,

2024).) 1 These TitleMax entities include TitleMax of Ohio, Inc.; TitleMax of Delaware, Inc.; and TitleMax of Virginia, Inc. (collectively with TMX Finance LLC and TitleMax Funding, Inc., “TitleMax”).2 None of these TitleMax

companies are Pennsylvania entities. (See Doc. 1 ¶¶ 19, 22.) A. Pennsylvania’s Usury Laws Pennsylvania’s Loan Interest and Protection Law (“LIPL”) prohibits usury by setting a maximum permissible interest rate of six percent per annum on loans

under $50,000. 41 Pa. Stat. § 201(a). Lenders licensed by the Department, however, may exceed that six-percent limit under certain circumstances, pursuant to Pennsylvania’s Consumer Discount Company Act. See 7 Pa. Stat. §§ 6203(A), 6213. LIPL provides both a criminal and a civil penalty for violations of its

1 For ease of reference, the court uses the page numbers from the CM/ECF header.

2 CCFI Companies, LLC—a plaintiff in the related action CCFI Companies, LLC v. Spicher—is a subsidiary of TMX Finance’s parent company. (Compl. at 6, CCFI Cos., LLC v. Spicher, No. 24-CV-02134 (M.D. Pa. Aug. 13, 2024).) provisions. A knowing and intentional violation subjects the offender to a misdemeanor of the third degree. 41 Pa. Stat. § 505(a). Any violation of the

statute subjects the offender to a $10,000 fine per offense. Id. § 505(b). B. 2017 Subpoena and Associated Lawsuits In August 2017, the Department began investigating TitleMax for possible violations of Pennsylvania’s usury laws. It did so by issuing a subpoena to

TitleMax Funding’s principal place of business (“2017 Subpoena”). (Doc. 1, ¶ 34; Doc. 16-4.) In general, the 2017 Subpoena sought documents and records concerning loans that TitleMax entities made to Pennsylvania consumers. (Doc.

16-4, pp. 5–7.) TitleMax refused to comply with the 2017 Subpoena and, instead, filed a lawsuit in the United States District Court for the District of Delaware. See generally TitleMax of Delaware, Inc. v. Weissmann, 505 F. Supp. 3d 353 (D. Del. 2020). In that action, TitleMax argued that the Department’s investigative

subpoena was an attempt to extraterritorially enforce Pennsylvania’s usury laws in violation of, inter alia, the Commerce Clause. Id. at 354–55. The district court found in favor of TitleMax and deemed the Department’s actions unconstitutional.

Id. at 360. The Third Circuit, however, reversed and determined that the Department’s actions did not contravene the Commerce Clause’s extraterritoriality principle, because TitleMax’s actions did not wholly occur outside of Pennsylvania. TitleMax of Delaware, Inc. v. Weissmann, 24 F.4th 230, 239–40 (3d Cir. 2022).

Concurrently with that federal lawsuit, the Department filed an enforcement action in Pennsylvania Commonwealth Court to compel TitleMax’s response to some, but not all, of the 2017 Subpoena’s requests. See Pa. Dep’t of Banking &

Sec. v. TitleMax of Delaware, Inc., No. 417 M.D. 2017, slip op. at 5 (Pa. Commw. Ct. Feb. 22, 2023).3 Specifically, the Department sought the following information: (1) loan agreements and other agreements ancillary to loans between TitleMax and Pennsylvania consumers; (2) records relating to payments made by

Pennsylvania consumers to TitleMax for loan or pawn obligations; and (3) records involving TitleMax’s repossessions of vehicles owned by Pennsylvania consumers. Id. at 10–11. Following the Third Circuit’s decision, the Commonwealth Court

found in favor of the Department and ordered TitleMax to respond to the applicable requests. Id. at 23. TitleMax produced a response in accordance with the Commonwealth Court’s order. (Doc. 1, ¶ 38.) C. 2024 Subpoena and the Department’s Enforcement Proceeding

On June 7, 2024, the Department issued another subpoena to TitleMax (“2024 Subpoena”). (Doc. 1-1.) The 2024 Subpoena included requests for the same information TitleMax provided in response to the 2017 Subpoena, but was

3 This opinion is available at this case’s docket number 25-2. limited to the time period of “August 23, 2017 through the present.” (Id. at 4.) TitleMax does not allege that the Department has sought court intervention to

enforce the 2024 Subpoena. One week later, the Department initiated a civil enforcement action (“Pennsylvania Proceeding”) by issuing an order to show cause (“OSC”) to TitleMax.4 (See Doc. 1-2.) The OSC alleges that TitleMax charged interest rates

in excess of the LIPL’s six-percent limit, even though TitleMax was never licensed by the Department. (Doc. 1-2, p. 7.) The OSC accuses TitleMax of 5,270 violations of the LIPL between July 2008 and September 2017. (Id. at 7–8.) As

sanctions for TitleMax’s alleged conduct, the Department seeks a $10,000 fine for each of the alleged violations, for a total fine of $52,700,000. (Id. at 8.) D. TitleMax’s Federal Lawsuits TitleMax’s answer to the OSC was initially due on July 15, 2024. (See Doc.

1-2, p. 2.) On August 13, 2024, following extensions to the due date, TitleMax filed six federal lawsuits in six different districts—the Northern District of Georgia, the Southern District of Ohio, the Western District of Virginia, the

District of Delaware, the District of South Carolina, and the Northern District of

4 The OSC lists the following entities as respondents: “TitleMax of Delaware, Inc.; TitleMax of Ohio, Inc.; TitleMax of Virginia, Inc.; TitleMax of South Carolina, Inc.; TitleMax Funding, Inc.; TMX Finance LLC; TMX Finance Corporate Services, Inc.; CCFI Companies, LLC; and all successors or predecessors in interest, affiliates, subsidiaries, or parent companies, however named.” (Doc. 1-2, p. 2.) Texas—rather than answer the OSC. In each of the lawsuits, TitleMax alleges that the Department, through the OSC, is attempting to extraterritorially apply

Pennsylvania’s usury laws in violation of the Commerce Clause and the Due Process Clause. (E.g., Doc. 1, pp. 21–27.) Moreover, TitleMax claims that the Department defectively served the 2024 Subpoena in violation of the Full Faith

and Credit Clause and the Equal Protection Clause. (E.g., id.

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