WEST v. GLOBAL LENDING SERVICES, LLC

CourtDistrict Court, E.D. Pennsylvania
DecidedMay 28, 2025
Docket2:24-cv-06726
StatusUnknown

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

Bluebook
WEST v. GLOBAL LENDING SERVICES, LLC, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

CIONJA WEST, CIVIL ACTION Plaintiff,

v.

GLOBAL LENDING SERVICES, LLC, et NO. 24-6726 al., Defendants.

MEMORANDUM OPINION Plaintiff Cionja West, proceeding pro se, brought suit against Defendants Global Lending Services, LLC (“Global Lending”), International Recovery Systems, LLC (“International Recovery”), and PAR, Inc. d/b/a PAR North America, improperly named as PAR North America, LLC (“PAR”), due to the repossession of her car. In her Third Amended Complaint, she alleges violations of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692, et seq.; the Fair Credit Reporting Act, 15 U.S.C. § 1681b, et seq.; the Gramm-Leach-Bliley Act, 15 U.S.C. §§ 6801-6809; the California Consumer Privacy Act, Cal. Civ. Code § 1798, et seq.; the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. § 1961, et seq.; unidentified constitutional claims under 42 U.S.C. §§ 1983, 1985, and 1986; and common law invasion of privacy. Defendants move to dismiss the Third Amended Complaint in its entirety for failure to state a claim pursuant to Federal Rule of Civil Procedure 12(b)(6). For the reasons that follow, Defendants’ Motion will be granted. BACKGROUND The following factual recitation is taken from West’s operative Complaint, well-pleaded allegations from which are taken as true at this stage. Fowler v. UPMC Shadyside, 578 F.3d 203, 210-11 (3d Cir. 2009). In 2021, West bought a Hyundai Santa Fe, financing the purchase by entering a “consumer credit transaction” with Global Lending. Three years later, PAR and International Recovery, on behalf of Global Lending, repossessed the car while it was parked at a family member’s residence, without notifying West that the car was subject to repossession. To locate

and repossess the vehicle, PAR accessed her credit report. A week after the repossession, Global Lending wrote to West, informing her of her options should she wish to recover the vehicle, although West’s pleading does not reveal if she tried to do so. At some point, Global Lending decided to write off the debt that West owed on the car, but failed to provide her with a “1099-C form,” which, as she sees it, Global Lending was required by law to do. According to West, when Global Lending reported the loss to the Internal Revenue Service, it “effectively treated the debt as uncollectible. However, [Global Lending] still engaged [PAR] and International Recovery . . . to repossess the vehicle unlawfully.” In the wake of the car’s repossession and Global Lending writing off the debt, West sent two “formal requests”—in the form of emails—to Global Lending, which sought information regarding the

“sale and disclosure” of her personal information. Global Lending declined to respond. LEGAL STANDARDS “To survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Id. When analyzing a motion to dismiss, the complaint must be construed “in the light most favorable to the plaintiff,” with the question being “whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.” Fowler, 578 F.3d at 210 (citation omitted). Legal conclusions are disregarded, well-pleaded facts are taken as true, and a determination is made as to whether those facts state a “plausible claim for relief.” Id. at 210-11.

Because West is proceeding pro se, her allegations must be construed liberally at this stage. See Vogt v. Wetzel, 8 F.4th 182, 185 (3d Cir. 2021) (citing Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 244-45 (3d Cir. 2013)). The “relevant legal principle” therefore will be applied “even when the complaint has failed to name it.” Id. “Missing details or superfluous material” similarly do not render a pro se complaint “unintelligible.” Garrett v. Wexford Health, 938 F.3d 69, 93-94 (3d Cir. 2019). “Indeed, even if it is vague, repetitious, or contains extraneous information, a pro se complaint’s language will ordinarily be ‘plain’” in satisfaction of Rule 8 “if it presents cognizable legal claims to which a defendant can respond on the merits.” Id. at 94 (citations omitted). DISCUSSION

A. Fair Debt Collection Practices Act First, West alleges that Defendants violated the Fair Debt Collection Practices Act (the “FDCPA”), 15 U.S.C. § 1692, et seq. To prevail on that claim, West must allege facts establishing “that (1) she is a consumer, (2) the [Defendants are] debt collector[s], (3) the [Defendants’] challenged practice involves an attempt to collect a ‘debt’ as the Act defines it, and (4) the [Defendants] violated a provision of the FDCPA in attempting to collect the debt.” Douglass v. Convergent Outsourcing, 765 F.3d 299, 303 (3d Cir. 2014).1

1 Defendants primarily argue—regarding both West’s FDCPA claim and most of the claims addressed below—that her Third Amended Complaint is a cut-and-paste of her Amended Complaint, which was dismissed without prejudice. As Defendants see it, because West’s Amended Complaint was previously dismissed, and because West West has failed to allege facts supporting the fourth element, that Defendants violated one of the FDCPA’s provisions in collecting on her debt, because she does not describe said violations other than in conclusory terms. For example, she asserts the legal conclusion that Defendants “misrepresent[ed] their legal right to repossess” her “vehicle and engag[ed] in

deceptive practices to enforce a nonexistent right to possession,” purportedly in violation of the FDCPA’s prohibition on making “false, deceptive, or misleading representation[s]” in connection with debt collection. 15 U.S.C. § 1692e.

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Bluebook (online)
WEST v. GLOBAL LENDING SERVICES, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/west-v-global-lending-services-llc-paed-2025.