Jefferson v. JPMorgan Chase Bank, N.A.
8:24-cv-02939
D. MarylandJun 4, 2025Background
- Keona Jefferson purchased a used 2020 Cadillac Escalade on credit from AutoNation Chevrolet Laurel.
- The purchase involved a retail installment contract with 75 monthly payments; AutoNation assigned its interest to JPMorgan Chase Bank (Chase), becoming the creditor.
- Jefferson’s vehicle was repossessed on June 17, 2024, allegedly without proper notice.
- After the repossession, Jefferson sent Chase a demand for documentation and assurance of performance; she asserts Chase did not respond adequately.
- Jefferson filed suit, claiming violations of the Fair Debt Collection Practices Act (FDCPA), breach of contract, intentional infliction of emotional distress, and misuse of personally identifiable information (PII).
- Chase moved to dismiss all claims under Rule 12(b)(6) for failure to state a claim.
Issues
| Issue | Plaintiff’s Argument | Defendant’s Argument | Held |
|---|---|---|---|
| FDCPA applicability to Chase | Chase violated FDCPA in attempt to collect a debt | Chase is not a "debt collector" per FDCPA definition | Dismissed: Chase not a "debt collector" |
| Breach of contract under UCC § 2-609 | Chase failed to provide adequate assurance of performance | UCC § 2-609 inapplicable; no private right of action | Dismissed: Claim not plausible under UCC |
| Intentional infliction of emotional distress (IIED) | Repossession caused severe distress and embarrassment | No extreme/outrageous conduct; distress not sufficiently severe | Dismissed: Insufficient facts pled |
| Violation of economic rights/PII | Chase misused PII under Maryland law | No such tort exists; no legal basis or facts pled | Dismissed: Not a recognized claim |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for plausibility under Rule 12)
- Albright v. Oliver, 510 U.S. 266 (1994) (pleadings reviewed in light most favorable to plaintiff)
- Henson v. Santander Consumer USA, Inc., 817 F.3d 131 (4th Cir. 2016) (FDCPA definition does not cover creditors collecting their own debts)
- Heintz v. Jenkins, 514 U.S. 291 (1995) (FDCPA applies to attorneys engaged in debt collection, but not to banks as creditors)
- Harris v. Jones, 380 A.2d 611 (Md. 1977) (elements for IIED under Maryland law)
- Hamilton v. Ford Motor Credit Co., 502 A.2d 1057 (Md. Ct. Spec. App. 1986) (IIED standard in debt repossession context)