Witz v. Great Lakes Educational Loan Services, Inc.

CourtDistrict Court, N.D. Illinois
DecidedJune 24, 2025
Docket1:19-cv-06715
StatusUnknown

This text of Witz v. Great Lakes Educational Loan Services, Inc. (Witz v. Great Lakes Educational Loan Services, Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Witz v. Great Lakes Educational Loan Services, Inc., (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JEFFREY W. WITZ, on behalf of himself and others similarly situated,

Plaintiff, No. 19-cv-06715

v. Judge John F. Kness

GREAT LAKES EDUCATIONAL LOAN SERVICES, INC.,

Defendant.

MEMORANDUM OPINION AND ORDER Plaintiff Jeffrey Witz borrowed money from the federal government to pay for his education. Defendant Great Lakes Educational Loan Services, Inc., manages repayment of federally insured loans for millions of student borrowers, including Plaintiff. Plaintiff sued Defendant on behalf of a purported class of similarly situated borrowers.1 Plaintiff has refiled his complaint for the third time (the operative version is entitled the “Second Amended Complaint”), alleging violations of the Illinois Consumer Fraud Act (“ICFA”), unjust enrichment, and common law fraud. (Dkt. 88.) Defendant now moves to dismiss the Second Amended Complaint and argues that Plaintiff lacks standing, fails to state a claim for relief, and has improperly recast a

1 The Court has subject matter jurisdiction under the Class Action Fairness Act, 28 U.S.C. § 1332(d)(2), because this suit has been brought on behalf of proposed classes, each in excess of one hundred members; the aggregate claims of the Class members exceed $5 million exclusive of interest and costs; and one or more of the members of each Class is a citizen of a different state than one or more Defendants. claim for negligent misrepresentation as a claim for unjust enrichment. (Dkt. 93.) Defendant also moves to strike the class allegations for each of Plaintiff’s claims. (Dkt. 92.) For the reasons stated below, Defendant’s motion is granted in part and

denied in part. I. BACKGROUND As the Court has previously summarized (Dkt. 87), Defendant Great Lakes Educational Loan Services, Inc. (“Great Lakes”) is a Wisconsin corporation that contracts with the United States Department of Education to service federal student loans. (Dkt. 88 ¶ 6.) As part of its servicing responsibilities, Defendant collects loan payments, administers repayment programs on behalf of the Department of

Education, and agrees to comply with the federal law and the Department’s regulations. (Dkt. 88 ¶ 11.) Among various repayment options, Defendant offers an income-driven repayment (“IDR”) plan, which allows borrowers to make monthly payments to Defendant based on their income, occupation, and family size. (Id.) IDR plans also allow borrowers to apply for loan forgiveness after a certain number of qualifying payments. (Id.) IDR plans are, in relevant part, divided between income-

contingent plans, known as Pay As You Earn (“PAYE”) plans, and income-based repayment (“IBR”) plans. See 34 C.F.R. § 685.209 (PAYE plans); 34 C.F.R. § 685.221 (IBR plans).2

2 Both PAYE and IBR plans allow prepayment “at any time without penalty, as provided under § 685.211(a)(2).” Id. §§ 685.209(a)(3)(ii) (PAYE), 685.221(c)(2) (IBR). Section 685.211(a)(2) specifies that “[i]f a borrower pays any amount in excess of the amount due, the excess amount is a prepayment.” Id. § 685.211(a)(2). In May 2018, Plaintiff Jeffrey Witz held five loans under an IBR plan serviced by Defendant, numbered 721, 722, 723, 724, and 726. (Dkt. 88 ¶¶ 13–14.) Plaintiff’s minimum required monthly payment under the IBR plan was $394.41. (Id. ¶ 17; Dkt.

88-1.) Plaintiff alleges that Defendant represented on its website that the “rules require that outstanding interest . . . must be paid first, prior to a payment being applied to the loan principal[,]” but “when it comes to excess payments [borrowers] have more flexibility.” (Dkt. 88 ¶ 26.) Defendant’s webpage further provided: We automatically apply excess to:

1. Accrued interest since your last payment. 2. Principal of the loan with the highest interest rate.

Note: If you're in school, grace, or deferment, after outstanding interest for all loans has been paid it will be applied to the unsubsidized loan with the highest interest rate.

If you prefer the excess to be applied to a different loan or loans within the account, define your Excess Payment Preference. This can be done for just one excess payment or for all future excess payments. . . . (Id.) Before May 2018, Plaintiff made regular monthly payments that were equal to or exceeded the current amount due under his IBR plan. (Id. ¶ 16.) In that period, Defendant applied Plaintiff’s minimum monthly payments only to interest. (Id. ¶ 18.) By May 2018, however, Plaintiff noticed that the $394.41 payment represented “slightly more than the interest accruing on the loans each month.” (Id. ¶ 19.) To pay off the loans as quickly as possible and to minimize the amount of interest paid, Plaintiff began to make monthly payments in excess of the required minimum (“prepayments”). (Id. ¶ 20.) Starting in May 2018, Plaintiff made $1,000 monthly payments to Defendant, approximately $606.59 above the required minimum. (Id. ¶ 21.) Plaintiff submitted the $1,000 payments based on Defendant’s representation on its website. (Id. ¶ 29.) Between May 2018 and June 2019, Defendant applied approximately $400 to interest and $600 to principal out of each

of Plaintiff’s $1,000 payments. (Id. ¶ 22.) By regularly making such prepayments, Plaintiff paid off Loan 721 by July 2019. (Id. ¶ 23.) But when Plaintiff made another $1,000 monthly payment in July 2019, Defendant applied the full amount towards interest on Loan 723, applying none to the principal. (Id. ¶ 25.) Plaintiff alleges that Defendant did not apply the excess payments in accordance with the representations on its website. Plaintiff states that when he inquired as to why none of his excess payments had been applied to the principal of

Loan 723, Defendant responded that Plaintiff needed to “pay off 100% of the interest on Loan 723 before anything would be applied to principal or the note.” (Id. ¶ 31.) Because the outstanding interest on Loan 723 that had accrued under Plaintiff’s IBR plan exceeded $1,000, Defendant applied the entirety of the payment to the interest amount. (Id.) Plaintiff alleges that the application of the entire payment to outstanding interest on Loan 723 was inconsistent “with the representations on Great

Lakes’ website” because the website assured Plaintiff “that any excess payment [would be] applied first to interest accumulation since the last payment and then to principal.” (Id. ¶ 33.) Plaintiff also alleges that Defendant failed to apply prepayments in accordance with federal law. (Id. ¶ 39.) Plaintiff alleges that Defendant’s representations on its website “deceive[s] borrowers into believing that all payments made in excess of the required monthly payment will be applied to the principal” of an outstanding loan, which borrowers believe will shorten the length of the repayment plan and “thereby reduce the overall accrued interest[.]” (Id. ¶ 34.) Plaintiff further states that, because of Defendant’s

deception, the principal balance of borrowers’ loans “is higher than it should be or would be had Great Lakes applied prepayments in accordance with its representations,” and Plaintiff, along with similarly situated borrowers, have been “charged interest on the higher principal.” (Id. ¶ 35.) Following an oral motion to amend the initial complaint in this case (Dkt. 26), Plaintiff filed an amended complaint containing claims for breach of contract, violations of the ICFA, negligent misrepresentation, and common law fraud. (Dkt.

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Witz v. Great Lakes Educational Loan Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/witz-v-great-lakes-educational-loan-services-inc-ilnd-2025.