Wickard, L. v. Belco Com. Credit Union

2025 Pa. Super. 195
CourtSuperior Court of Pennsylvania
DecidedSeptember 4, 2025
Docket1355 MDA 2024
StatusPublished

This text of 2025 Pa. Super. 195 (Wickard, L. v. Belco Com. Credit Union) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wickard, L. v. Belco Com. Credit Union, 2025 Pa. Super. 195 (Pa. Ct. App. 2025).

Opinion

J-A15038-25

2025 PA Super 195

LOUIS WICKARD, BRADLEY : IN THE SUPERIOR COURT OF ESPENSHADE, INDIVIDUALLY AND : PENNSYLVANIA ON BEHALF OF ALL OTHERS : SIMILARLY SITUATED : : Appellant : : : v. : No. 1355 MDA 2024 : : BELCO COMMUNITY CREDIT UNION :

Appeal from the Order Entered September 4, 2024 In the Court of Common Pleas of Lancaster County Civil Division at No(s): CI-22-06167

BEFORE: BOWES, J., STABILE, J., and STEVENS, P.J.E.*

OPINION BY STEVENS, P.J.E.: FILED: SEPTEMBER 4, 2025

Plaintiffs/Appellants, Louis Wickard and Bradley Espenshade, appeal

from the order entered in the Court of Common Pleas of Lancaster County on

September 4, 2024, granting summary judgment in favor of

Defendant/Appellee, Belco Community Credit Union. After a careful review,

we affirm.

The trial court summarized the relevant facts and procedural history as

follows:

This action arises from notice received by Plaintiffs following the repossession of their vehicles by Belco subsequent to default in payments pursuant to financial agreements each Plaintiff made with Belco. Amended Class Action Complaint (“Am. Compl.”), 7/31/2023 at 3, 4. On July 31, 2023, Plaintiffs filed the instant ____________________________________________

* Former Justice specially assigned to the Superior Court. J-A15038-25

amended complaint alleging Belco regularly finances the purchases of automobiles for consumer use and should consumers default on their secured finance agreements they will repossess the vehicle. Id. at 1. Plaintiffs Wickard and Espenshade assert they entered into sale contracts with Belco for the purpose of purchasing used vehicles. Id. at 3, 4. In said agreements Plaintiffs acknowledged that should they default by failing to make payments, Belco may retake their vehicles and sell them to recoup losses. Id., Ex. A, at 3-4; Ex. C, at 3.

Both Wickard and Espenshade defaulted on their finance agreements and their vehicles were repossessed by Belco. Compl. at 3, 4. Subsequent to the repossession of the vehicles, Belco sent each Plaintiff a “NOTICE OF OUR PLAN TO SELL PROPERTY” (“Notice”). Id. [Exhibits] B, D. Plaintiffs contend that the Notice “did not provide an accurate description of the debtor’s liability for a deficiency because Belco states that the sale proceeds may be reduced by ‘reasonable attorney’s fees and court costs.’” Id. at 3. As such, Plaintiffs bring forth one count, that Belco violated Pennsylvania’s Uniform Commercial Code (“UCC”), specifically, 13 Pa.C.S.A. §§ 9610-9614, by failing to provide proper notice of repossession of collateral. Id. at 8.

On March 8, 2024, Belco moved for summary judgment asserting the Notice sent to Plaintiffs and similarly situated individuals was commercially reasonable because it met all of the notice requirements in sections 9613 and 9614 of the Pennsylvania UCC. MSJ at 5-6. Belco further asserted that it is not precluded from recovering reasonable attorney’s fees under the UCC. Id. at 6. In response, Plaintiffs argue that the Notice is misleading under the UCC and the Motor Vehicle Sales Finance Act (“MVSFA”) as they assert Pennsylvania law does not allow for the recovery of attorney’s fees in cases of nonjudicial repossession. CMSJ at 4.

In reply, Belco explained that the pre-sale Notice accurately described Plaintiffs’ liability following repossession, including any “reasonable attorney’s fees permitted by law.” Defendant Belco Community Credit Union’s Combined Reply Brief in Support of its Motion for Summary Judgment and Response to Plaintiff’s Cross- Motion for Summary Judgment, 6/3/2024, at 1. Belco further asserted that Plaintiffs failed to provide any evidence regarding how the mention of reasonable attorney’s fees in the Notice misled them when the Belco was simply providing its members with

-2- J-A15038-25

information concerning potential costs allowed by law that Belco may incur as a result of the repossessions. Id. at 1-2. On June 27, 2024, Plaintiffs filed a reply in support of their cross-motion for summary judgment which argued, inter alia, that Belco’s admission that it never incurs attorney’s fees for nonjudicial repossession shows that the notices sent to Plaintiffs is misleading and fails to provide an accurate description of potential liability as required under 13 Pa.C.S.A. § 9614, and that neither the UCC nor the MVSFA authorize the recovery of attorney’s fees in nonjudicial repossessions. Plaintiffs’ Reply in Support of Cross-Motion for Summary Judgment, 6/27/2024. On July 26, 2024, oral argument was held in response to the MSJ and CMSJ and the responses and replies thereto.

Tr. Ct. Op., 9/3/24, at 2-3.

Following oral argument, the trial court granted Belco’s motion for

summary judgment and denied Appellants’ cross-motion for summary

judgment by order docketed September 4, 2024. Appellants filed a timely

notice of appeal on September 17, 2024. Appellants filed a concise statement

pursuant to Pa.R.A.P. 1925(b) on October 10, 2024. This appeal follows.

Appellants raise three issues in their brief:

(1) The Motor Vehicle Sales Finance Act provides for recovery of lender attorney fees solely in the case of a repossession effected by judicial process, after legal proceedings are commenced. Did the trial court err in holding that Belco may demand and recover attorney fees in a nonjudicial, self-help auto repossession?

(2) Belco’s post-repossession notice stated that its attorney fees and court costs would be deducted from the proceeds of any auction sale in determining the consumer’s remaining deficiency balance. Where attorney fees were not permitted by statute or contract—and were not incurred by Belco—did the trial court err in finding that Belco provided an accurate “description of any liability for a deficiency” that Article 9 of the UCC requires?

(3) Did the trial court err in concluding as a matter of law that Belco’s post-repossession notice to the Consumers was not

-3- J-A15038-25

misleading as to the Consumers’ liability for a deficiency under Pennsylvania law?

Appellants’ Br. at 2-3.

Our scope and standard of review of a court’s ruling on a motion for

summary judgment is as follows:

Our scope of review of a trial court’s order disposing of a motion for summary judgment is plenary. . . . Our standard of review is the same as that of the trial court; thus, we determine whether the record documents a question of material fact concerning an element of the claim or defense at issue. If no such question appears, the court must then determine whether the moving party is entitled to judgment on the basis of substantive law.

Stanton v. Lackawanna Energy, Ltd., 820 A.2d 1256, 1258 (Pa. Super.

2003).

We begin by clarifying the positions of the parties and highlighting

several additional relevant facts. Appellants do not dispute that they defaulted

on their finance agreements. Appellants acknowledge that their defaults in

payments properly resulted in the repossession of their vehicles and rendered

them liable to Belco for certain repossession costs under their contracts and

under Pennsylvania law. It is undisputed that Belco never sought to recover

attorney’s fees from Appellants as part of those repossession costs, and Belco

has never asserted that any attorney’s fees were incurred by them in the

process of repossessing Appellants’ vehicles. Thus, this is not a case where

Appellants are contesting the amount of attorney’s fees owed; they owe none.

Under the governing Pennsylvania statute, Belco, as the secured party

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Beneficial Consumer Discount Co. v. Savoy
436 A.2d 687 (Superior Court of Pennsylvania, 1982)
Dept. of Transp. v. Manor Mines, Inc.
565 A.2d 428 (Supreme Court of Pennsylvania, 1989)
Stanton v. Lackawanna Energy, Ltd.
820 A.2d 1256 (Superior Court of Pennsylvania, 2003)
Savoy v. Beneficial Consumer Discount Co.
468 A.2d 465 (Supreme Court of Pennsylvania, 1983)
Rendell v. Pennsylvania State Ethics Commission
983 A.2d 708 (Supreme Court of Pennsylvania, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Pa. Super. 195, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wickard-l-v-belco-com-credit-union-pasuperct-2025.