Trimble v. American First Finance

CourtDistrict Court, D. Maryland
DecidedFebruary 21, 2025
Docket1:24-cv-00969
StatusUnknown

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

Bluebook
Trimble v. American First Finance, (D. Md. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

KAITLYN TRIMBLE, individually, and on * behalf of all others similarly situated, * Plaintiff, v. * Civil Action No. RDB-24-0969 AMERICAN FIRST FINANCE, LLC, * Defendant. * * * * * * * * * * * * * * MEMORANDUM ORDER This case arises out of a contract dispute between Plaintiff Kaitlyn Trimble (“Plaintiff” or “Trimble”) and Defendant American First Finance, LLC (“Defendant” or “American First”), which provided a payment plan to finance Trimble’s purchase of several items of furniture. (ECF No. 4 ¶ 26). On March 1, 2024, Trimble initiated an action against American First in the Circuit Court for Prince George’s County, Maryland, by filing a two-count Complaint alleging violations of the Maryland Consumer Loan Law (“MCLL”) (Count I) and the Maryland Rental-Purchase Agreement Act (“MRPAA”) (Count II). (ECF No. 4.) On April 3, 2024, Defendant timely removed the case to this Court, which has diversity jurisdiction pursuant to both 28 U.S.C. § 1332(a) and the Class Action Fairness Act of 2005, 28 U.S.C. §§ 1332(d), 1453. (ECF No. 1.) Currently pending before this Court is Defendant’s Motion to Compel Arbitration (“Defendant’s Motion”).1 (ECF No. 15.) Plaintiff has responded in opposition (ECF No.

1 Defendant’s initial motion was a Motion to Compel and Dismiss. (ECF Nos. 15, 16.) However, in its reply, Defendant requested the Court only consider its motion as a Motion to Compel in accordance with a ruling from the United States Supreme Court instructing district courts to stay—rather than dismiss—underlying 20), and Defendant has replied (ECF No. 21). The parties’ submissions have been reviewed, and no hearing is necessary. Lc. R. 105.6 (D. Md. 2023). For the forthcoming reasons, Defendant’s Motion to Compel Arbitration (ECF No. 15) is GRANTED, and this case is

STAYED pending the completion of the arbitration process. BACKGROUND Trimble’s claims relate to her “rental-purchase” contract with American First, a company that “contracts with third-party merchants…to provide alternative” payment options for the third-party retailer’s customers. (ECF No. 4 ¶¶ 27, 4). On July 14, 2023, Trimble purchased several items of furniture, including a mattress, mattress protectors, storage

drawers, headboard, footboard, rail, and bed foundation from furniture retailer American Freight, who partners with American First. (Id. ¶¶ 98–101.) In so doing, she signed a six- paged Consumer Rental-Purchase Agreement (“Agreement”) that stated a total cash price of $1,779.94. (ECF No. 16, Ex. 2.). This Agreement also included a “delivery fee” of $209.99 and a “processing fee” with tax that totaled an additional $53.00. (Id.) On its third page, the Agreement provided that “no changes may be made to this Agreement except by us in writing”

(the “Change Clause”). (ECF No. 16, Ex. 2 ¶ 21.) The Agreement also contained an Arbitration Provision that allows either party to invoke arbitration as to “any claim, dispute, or controversy” arising under or relating to the Agreement. (ECF No. 16 at 2.) The provision provided, in relevant part:

actions pending completion of arbitration. (ECF No. 21); see Smith v. Spizzirri, 601 U.S. 472, 475–76, 144 S. Ct. 1173, 1177–78 (2024) (“When a federal court finds that a dispute is subject to arbitration, and a party has requested a stay of the court proceeding pending arbitration, the court does not have discretion to dismiss the suit...”). Because Defendant now requests a stay of the case until the conclusion of the arbitration proceedings (ECF No. 21), this Court construes Defendant’s Motion as a Motion to Compel Arbitration only. [The Arbitration Provision] sets forth when and how claims…will be arbitrated instead of litigated in court. This arbitration provision governs “claims” you assert against us or any “related party” of ours and “claims” we or any related party assert against you….Unless prohibited by applicable law and unless you reject the Arbitration Provision…you and we agree that either party may elect to require arbitration of any Claim… (Id.) The Arbitration Provision explained Trimble’s right to reject arbitration “within 30 days after the date of this Agreement,” and provided that such rejection “will not affect your right to Services or the terms of this Agreement (other than the Arbitration Provision).” (Id.) The Arbitration Provision also included a “Delegation Clause,” which noted that “any dispute or argument that concerns the validity or enforceability of the Agreement as a whole is for the arbitrator, not a court, to decide.” (Id.) Though Trimble paid off the account “in full” after about five months, she ultimately paid Defendant a total of $2,457.87 for the merchandise. (ECF No. 4 ¶ 6.) On March 1, 2024, Trimble filed a class action complaint2 in the Circuit Court for Prince George’s County against American First on behalf of herself and other similarly situated Maryland consumers, alleging violations of Maryland state law, including the Maryland Consumer Loan Law (“MCLL”) and the Maryland Rental-Purchase Agreement Act (“MRPAA”). (ECF No. 4.).3 On April 3, 2024,

2 Trimble “requests certification of a class of similarly situated persons.” (ECF No. 4 at 5.) The Arbitration Provision also includes a class action waiver wherein the right to “participate in a class action in court or in arbitration, either as a class representative, class member or class opponent” is disallowed. (ECF No. 16 at 5 ¶ 7.) As further explained below, because this Court finds the Arbitration Provision valid, this waiver applies, and Trimble must individually arbitrate. See Am. Exp. Co. v. Italian Colors Rest., 570 U.S. 228, 238–39, 133 S. Ct. 2304 (2013) (holding that the FAA permits waivers of class arbitrations where there is a valid arbitration agreement). 3 Trimble alleges in her complaint that American First essentially extends credit when it offers rental-purchase agreements through its partners that are designed to function as loans and evade Maryland state usury laws (ECF No. 4 at 11), saying that in her transaction, “American First used a purported ‘rental purchase ‘ form of transaction to disguise what was, in actuality, a loan.” (Id. at 3 ¶ 9.) She asserts that American First “does not comply with Maryland’s laws regulating either consumer rental-purchase agreements or loans.” (ECF No. 4 ¶ 2.) American First removed the action to this Court, pursuant to 28 U.S.C. § 1332(a)(1) and the Class Action Fairness Act of 2005 in 28 U.S.C. §§ 1332(d), 1453.4 (ECF No. 1.) American First then filed a Motion to Compel Arbitration and to Dismiss on May 3, 2024 (ECF Nos.

15, 16). Trimble responded in opposition on June 7, 2024, (ECF No. 20), and American First replied (ECF No. 21). This matter is now ripe for review. STANDARD OF REVIEW As Judge Chuang of this Court has previously explained, “Judges in this District have recognized that ‘motions to compel arbitration exist in the netherworld between a motion to dismiss and a motion for summary judgment.’” Cherdak v. ACT, Inc., 437 F. Supp. 3d 442, 454 (D. Md. 2020) (quoting Caire v. Conifer Value Based Care, LLC, 982 F. Supp. 2d 582, 589 (D.

Md. 2013)).

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Trimble v. American First Finance, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trimble-v-american-first-finance-mdd-2025.