Hampton v. Wells Fargo Bank, N.A.

Summary

The United States District Court for the District of Maryland granted Wells Fargo Bank, N.A.’s motion to dismiss Katrina Toya Hampton’s claims arising from her mortgage loan. The court rejected Hampton’s purported “redemption” theory, including her attempt to satisfy the mortgage through an alleged UCC Contract Trust Account, credit authorization, and bill of exchange. The court held that her claims for unjust enrichment, breach of contract, and promissory estoppel were not plausibly stated and dismissed the action with prejudice.

Holdings

1. The court had diversity jurisdiction because Hampton sought $645,000 in damages and discharge of a mortgage obligation exceeding $75,000, and the parties were citizens of different states.
2. Hampton could not discharge or satisfy her mortgage obligation through purported self-created credit, a UCC Contract Trust Account, or a bill of exchange, and her redemption theory had no legal or factual basis.
3. Hampton failed to state an unjust-enrichment claim because she did not allege that she conferred a benefit on Wells Fargo or that Wells Fargo was enriched by her nonpayment of the mortgage obligation.
4. Hampton failed to plausibly allege that a contract was formed through her purported use of self-created credit to satisfy the mortgage obligation.
5. Hampton failed to state a promissory-estoppel claim because she did not identify an actionable promise or reasonable reliance supporting enforcement.

Questions Presented

1. Whether the court had diversity subject-matter jurisdiction over the removed action.
2. Whether Hampton's claims based on the alleged use of self-created credit, a purported bill of exchange, and a redemption theory stated claims for unjust enrichment, breach of contract, or promissory estoppel under Rule 12(b)(6).

Disposition

dismissed