WADDELL v. TITLEMAX OF VIRGINIA, INC.
1:23-cv-00034
| M.D.N.C. | Jun 30, 2025Background
- Plaintiffs are North Carolina residents who obtained car title loans from TitleMax and related entities, alleging the loans exceeded state usury and consumer finance limits.
- Plaintiffs allege defendants' failure to disclose the loans’ illegality constituted unfair and deceptive trade practices.
- Plaintiffs’ loan contracts contained arbitration provisions covering their current claims, and Plaintiffs moved to compel arbitration and stay the case.
- Defendants responded to the motion, but did not argue the merits, instead requesting time to do so if their jurisdictional challenge failed.
- The Court denied Defendants’ motion to dismiss for lack of personal jurisdiction and proceeded to consider Plaintiffs’ motion to compel arbitration.
- The Court followed local rules regarding briefing and found Defendants did not appropriately request additional time to oppose the arbitration motion on the merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the case should be compelled to arbitration | Arbitration provision covers claims | Requested more time if jurisdiction was denied | Arbitration compelled; motion granted |
| Existence and validity of an arbitration agreement | Loan contracts contain valid agreement | Admitted arbitration clause exists | Agreement is valid and controls |
| Arbitrability of dispute under FAA | Claims fall within scope of agreement | Did not contest on merits | Dispute is arbitrable under FAA |
| Defendants’ entitlement to further time to oppose motion | No proper request for extension filed | Sought extra time informally if needed | No additional time granted; arguments considered |
Key Cases Cited
- Patten Grading & Paving, Inc. v. Skanska USA Bldg., 380 F.3d 200 (4th Cir. 2004) (describing strong policy favoring arbitration under FAA)
- Chorley Enters., Inc. v. Dickey’s Barbecue Rests., Inc., 807 F.3d 553 (4th Cir. 2015) (setting standard for compelling arbitration)
- Am. Gen. Life & Accident Ins. Co. v. Wood, 429 F.3d 83 (4th Cir. 2005) (explaining FAA elements for compelling arbitration)
- Levin v. Alms & Assocs., Inc., 634 F.3d 260 (4th Cir. 2011) (no party required to arbitrate absent clear agreement)
- United States v. Bankers Ins. Co., 245 F.3d 315 (4th Cir. 2001) (upon finding valid arbitration agreement, court must compel arbitration and stay proceedings)