Mason v. Iowa Student Loan Liquidity Corporation
4:23-cv-00515
S.D. IowaMay 19, 2025Background
- Plaintiffs (Mason, Carstensen, Gibson, McDonald, and Zambrano) sought leave to file a consolidated class action complaint against Iowa Student Loan Liquidity Corporation.
- Magistrate Judge granted plaintiffs’ motion on March 26, 2025.
- Defendant, Iowa Student Loan Liquidity Corporation, appealed magistrate’s order and also requested a stay.
- Plaintiffs opposed (resisted) the defendant’s appeal.
- District court reviewed the magistrate judge’s ruling for clear error or application of incorrect legal standards.
- The district court ultimately affirmed the magistrate judge’s order and denied the defendant’s request for a stay.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard for overturning magistrate on nondispositive matter | Order was correct and should be upheld | Magistrate’s order was clearly erroneous or unlawful | Order upheld |
| Whether consolidated class complaint can proceed | Good cause to consolidate claims | Consolidation inappropriate or prejudicial | Consolidation allowed |
| Request for Stay | No grounds for stay | Stay warranted while appeal is reviewed | Stay denied |
| Relevant standard review (clear error/contrary to law) | Magistrate applied correct legal standard | Magistrate misapplied law or facts | No misapplication found |
Key Cases Cited
- Ferguson v. United States, 484 F.3d 1068 (8th Cir. 2007) (sets standard for district court’s review of magistrate judge’s rulings on nondispositive pretrial matters)
- Doyle v. Graske, 579 F.3d 898 (8th Cir. 2009) (explains what qualifies as clearly erroneous finding by a court)
- McAllister v. United States, 348 U.S. 19 (1954) (defines clearly erroneous standard for appellate review)