Summary
The United States District Court for the Northern District of California grants GreenSky's motion for partial summary judgment concerning performance-fee recoveries sought by named plaintiff Heidi Barnes. Interpreting California Civil Code section 1789.21(a), the Court holds that the Credit Act does not permit recovery of amounts paid that did not result in injury and are unrelated to the injury conferring statutory standing. The Court distinguishes actual damages from the statute's amount-paid floor and concludes that performance-fee amounts cannot be recovered based solely on alleged injury from transaction fees.
Court
United States District Court for the Northern District of California
Jurisdiction
United States District Court for the Northern District of California
Decision date
October 28, 2025
Docket number
3:20-cv-01693
Disposition
affirmed
Questions Presented
- Whether the California Credit Services Act permits a consumer to recover as damages amounts paid that did not result in injury and are unrelated to the injury conferring statutory standing to sue.
- Whether Plaintiffs are entitled to relief under Federal Rule of Civil Procedure 56(d) to obtain additional discovery on performance-fee injury.
Holdings
- The Credit Act does not permit recovery of amounts paid that did not result in injury and are unrelated to the injury conferring statutory standing to sue.
- Plaintiffs are not entitled to Rule 56(d) relief because no named plaintiff has standing to seek further discovery on performance-fee injury, and the request was untimely.
Court Document
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