Favors v. Synchrony Bank
- Katherine Menendez
- 0:24-cv-03063
- U.S. District Court · District of Minnesota
- 14
In Favors v. Synchrony Bank (II), Judge Menendez kept one retaliation claim alive, dismissed four others, and denied Favors’s summary-judgment motions.
Joseph Anthony Favors and Synchrony Bank. Favors’s ECOA retaliation claim may proceed, while his FCRA, FCBA, MHRA, and breach-of-contract claims were dismissed; his partial-summary-judgment motions were denied.
What happened
In Favors v. Synchrony Bank (II), Joseph Anthony Favors alleged that Synchrony Bank unlawfully reduced his credit limit and later reduced his available credit to zero after he sent dispute letters. He brought claims under federal credit laws, Minnesota’s Human Rights Act, and contract law.
The court allowed Favors’s Equal Credit Opportunity Act retaliation claim to proceed because his allegations were sufficient at the complaint stage. It dismissed his Fair Credit Reporting Act, Fair Credit Billing Act, Minnesota Human Rights Act, and breach-of-contract claims because he did not plead enough facts or, for the Human Rights Act claim, filed too late.
Judge Katherine Menendez granted in part and denied in part Synchrony’s motion to dismiss. She denied Favors’s motions for partial summary judgment, finding them premature as to the remaining claim and denying them as to the dismissed claims.
The detailed version
- Favors v. Synchrony Bank · No. 0:24-cv-03063
- Katherine Menendez
- Mar. 19, 2025
Background
Joseph Anthony Favors sued Synchrony Bank over reductions to the credit limit on his account. He alleged that Synchrony reduced his credit limit, ultimately reduced his available credit to $0.00, and did so in retaliation for letters in which he disputed the reductions. He asserted claims under the Equal Credit Opportunity Act (ECOA), the Fair Credit Reporting Act (FCRA), the Fair Credit Billing Act (FCBA), the Minnesota Human Rights Act (MHRA), and state-law breach of contract.
Synchrony moved to dismiss the complaint for failure to state a claim. Favors filed two motions for partial summary judgment, which ask the court to decide some issues without a trial when there is no genuine dispute about the facts.
ECOA retaliation claim
The court held that Favors adequately pleaded an ECOA retaliation claim. The ECOA prohibits a creditor from discriminating against an applicant because the applicant, in good faith, exercised a right under the Consumer Credit Protection Act. Favors alleged that Synchrony reduced his credit limit to zero after receiving his dispute letter. At the motion-to-dismiss stage, the court evaluated whether his allegations were sufficient, not whether Synchrony’s version of events or the evidence ultimately proved the claim.
The court also rejected Synchrony’s argument that Favors could not qualify as an “applicant” because he already had an account. It concluded that the relevant regulation includes a person who has received an extension of credit and therefore does not exclude existing account holders. The court denied Synchrony’s motion to dismiss the ECOA claim.
FCRA claim
The court granted the motion to dismiss the FCRA claim. Favors alleged that Synchrony violated the FCRA but did not explain how. In particular, he did not allege that a consumer reporting agency notified Synchrony of a dispute, that he disputed information with a consumer reporting agency, or that Synchrony failed to investigate such a dispute or investigated it improperly.
FCBA claim
The court granted the motion to dismiss the FCBA claim. The FCBA requires a creditor to take specified actions after receiving written notice of a qualifying billing error. The notice must identify the account, indicate that the consumer believes the statement contains a billing error, and explain the reasons for that belief.
The court found that Favors’s letters identified him and his account and stated that he believed there was a problem, but did not identify a billing error as defined by the FCBA. The letters challenged Synchrony’s reduction of his credit limit and requested validation, but the court concluded that a credit-limit reduction did not fit the statute’s definition of a billing error. As a result, the letters did not trigger Synchrony’s statutory duty to respond under the FCBA.
MHRA claim
The court granted the motion to dismiss the MHRA claim. First, it found that Favors did not explain what was discriminatory about Synchrony’s conduct or identify the discriminatory practice at issue. Second, the court concluded that the claim was filed after the MHRA’s one-year limitations period had expired. Even using May 18, 2023—the date the opinion identifies for Favors’s letter about the reduction—the court calculated that the limitations period expired before Favors filed his civil complaint on June 11, 2024. The court rejected Favors’s argument that a later letter in February 2024 restarted the limitations period.
Breach-of-contract claim
The court dismissed the breach-of-contract claim. Favors did not identify a contract with Synchrony in the complaint and did not allege specific facts showing that Synchrony breached any contract. The court noted that his briefing discussed contracts but did not supply the necessary allegations.
Summary-judgment motions and disposition
The court denied Favors’s two motions for partial summary judgment. It found summary judgment premature as to the remaining ECOA claim and denied the motions as to the dismissed claims.
The court granted in part and denied in part Synchrony’s motion to dismiss. The ECOA retaliation claim remained, while the FCRA, FCBA, MHRA, and breach-of-contract claims were dismissed. The opinion does not state that any dismissal was with or without prejudice.
Read the full 14-page opinion on CourtListener, the free public archive maintained by the Free Law Project.