Tower Credit, Inc. v. Smith

CourtUnited States Bankruptcy Court, M.D. Louisiana
DecidedMay 30, 2025
Docket24-01037
StatusUnknown

This text of Tower Credit, Inc. v. Smith (Tower Credit, Inc. v. Smith) is published on Counsel Stack Legal Research, covering United States Bankruptcy Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tower Credit, Inc. v. Smith, (La. 2025).

Opinion

UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF LOUISIANA

IN RE:

CARLA R. SMITH CASE NO. 24-10786 DEBTOR CHAPTER 7

TOWER CREDIT, INC. PLAINTIFF

V. ADVERSARY NO. 24-1037

CARLA R. SMITH DEFENDANT

MEMORANDUM OPINION

On May 28, 2025, the Motion to Dismiss Adversary Proceeding1 filed by the defendant, Carla R. Smith (“Ms. Smith”) and the Motion for Partial Summary Judgment2 filed by the plaintiff, Tower Credit, Inc. (“Tower”) came before the court. I. Factual Background Tower loaned $5,255.59 to Ms. Smith in 2012 secured by a 1999 Honda Accord.3 On March 20, 2014, a judgment was rendered in state court (“Judgment”) in favor of Tower and against Ms. Smith in the amount of $4,7798.19, plus interest from date of judicial demand at the rate of 29% until satisfied, attorney’s fees of 25% of the principal and interest, and court costs.4 The Judgment was revived by an order dated November 17, 2023.5 On September 17, 2024, Ms. Smith filed a chapter 7 bankruptcy case. Tower filed Proof of Claim No. 1, asserting an unsecured claim for $23,905.04 based on the Judgment. Tower also

1 P-21. 2 P-27 3 P-27, p. 4. 4 P-27, p. 6. 5 P-27, p. 7. filed a Complaint objecting to dischargeability of the debt owed it by Ms. Smith pursuant to 11 U.S.C. § 523(a)(2)(B).6 Ms. Smith filed an Answer, asserting several affirmative defenses and counterclaims.7 It is undisputed that Ms. Smith represented on her credit application that she shared a rental with family members and that her portion of the monthly rent was $150. At Ms. Smith’s

meeting of creditors on October 17, 2024, however, she contradicted this by representing that she paid $600 to $700 per month in rent at the time of the loan. Tower contends in its Complaint that the amount owed it by Ms. Smith pursuant to the Judgment should be held nondischargeable pursuant to 11 U.S.C. § 523(a)(2)(B) because it relied on Ms. Smith’s representation that her rent was $150 and that it would not have made the loan had it known Ms. Smith’s true rental obligation. Ms. Smith contends that she did not misrepresent her rent on her credit application, but that she was mistaken at the meeting of creditors several years later when trying to remember her rent from 2012. II. Ms. Smith’s Motion to Dismiss

Ms. Smith attached to her Motion to Dismiss her affidavit representing that her credit application was truthful and that she was simply mistaken at the meeting of creditors. Also attached to the Motion to Dismiss are affidavits from Ms. Smith’s mother, sister, and brother, which each attest that at the time of the Tower loan, Ms. Smith’s portion of the monthly rent was $150. Although Ms. Smith does not cite any statutory authority for dismissal, presumably she seeks dismissal pursuant to F.R.C.P. 12(b)(6) for failure to state a claim upon which relief can be granted; it is made applicable in adversary proceedings by F.R.B.P. 7012(b).

6 P-1. 7 P-5. In Dixon v. Garner,8 the court found: In considering a Fed. R. 12(b)(6) motion, a district court generally “must limit itself to the contents of the pleadings, including attachments thereto.” The court may also consider documents attached to either a motion to dismiss or an opposition to that motion when the documents are referred to in the pleadings and are central to a plaintiff's claims. If evidence is considered outside of the pleadings, and is not referred to therein, the motion should be converted into a motion for summary judgment.9 Similarly, in George v. SI Grp., Inc.,10 the Fifth Circuit discussed evidence upon which a court may rely; it held: “a Rule 12(b)(6) motion typically cannot rely on evidence outside the complaint.” C&C Inv. Props., L.L.C. v. Trustmark Nat'l Bank, 838 F.3d 655, 660 (5th Cir. 2016). True, a district court may rely on evidence outside the complaint, without converting the Rule 12(b)(6) motion into a motion for summary judgment, if that evidence is either (a) a document attached to the Rule 12(b)(6) motion, referred to in the complaint, and central to the plaintiff's claim; or (b) a matter subject to judicial notice under Federal Rule of Evidence 201. See Walker v. Beaumont Indep. Sch. Dist., 938 F.3d 724, 735 (5th Cir. 2019). But going beyond the pleadings is otherwise error. See Brand Coupon Network, L.L.C. v. Catalina Mktg. Corp., 748 F.3d 631, 635 (5th Cir. 2014).

Ms. Smith’s Motion to Dismiss relies heavily on evidence outside the complaint and is therefore properly converted to a motion for summary judgment. F.R.B.P. 7056 makes F.R.C.P. 56 applicable in adversary proceedings in this court, so jurisprudence construing Rule 56 is equally applicable to motions under F.R.B.P. 7056. The Fifth Circuit ruled in Little v. Liquid Air Corp.11 that summary judgment under F.R.C.P. 56 is proper "if the pleadings, depositions, answers to interrogatories and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and the moving party is entitled to judgment as a matter of law."

8 In Dixon v. Garner, No. CV 17-564-EWD, 2019 WL 1370855 (M.D. La. Mar. 25, 2019). 9 Dixon, 2019 WL 1370855, at *9 (citing Brand Coupon Network, L.L.C. v. Catalina Marketing Corp., 748 F.3d 631, 635 (5th Cir. 2014)). 10 George v. SI Grp., Inc., 36 F.4th 611, 619 (5th Cir. 2022). 11 Little v. Liquid Air Corp., 37 F.3d 1069, 1075 (5th Cir. 1994) (en banc). The United States Supreme Court discussed which party bears the burden of proof in Celotex Corp. v. Catrett.12 It held: The burden of production imposed by Rule 56 requires the moving party to make a prima facie showing that it is entitled to summary judgment. 10A Wright, Miller & Kane § 2727. The manner in which this showing can be made depends upon which party will bear the burden of persuasion on the challenged claim at trial. If the moving party will bear the burden of persuasion at trial, that party must support its motion with credible evidence—using any of the materials specified in Rule 56(c)—that would entitle it to a directed verdict if not controverted at trial. Ibid. Such an affirmative showing shifts the burden of production to the party opposing the motion and requires that party either to produce evidentiary materials that demonstrate the existence of a “genuine issue” for trial or to submit an affidavit requesting additional time for discovery. Ibid.; Fed.Rules Civ.Proc. 56(e), (f).

As the moving party, Ms.

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