Greater Chautauqua Federal Credit Union v. Quattrone
- Vyskocil
- 1:22-cv-02753
- U.S. District Court · Southern District of New York
- 3
In Greater Chautauqua Federal Credit Union v. Quattrone, Judge Vyskocil denied without prejudice competing summary-judgment motions because disputed facts made summary judgment unsuitable.
The three plaintiff credit unions and the Sheriff and Attorney General defendants were affected because all pending summary-judgment motions were denied without prejudice. The parties were also ordered to attend a later conference, and the pending sealing motion was provisionally granted.
What happened
Greater Chautauqua Federal Credit Union v. Quattrone concerns three credit unions’ claim that New York’s retroactive reduction of post-judgment interest on certain consumer-debt judgments is unconstitutional as applied to them. The defendants include three county sheriffs and the state attorney general.
The parties filed competing requests for summary judgment, which asks a court to decide a case without a trial when no important facts are genuinely disputed. The court said the case is non-jury after the credit unions withdrew their jury demand, and its rules do not allow summary-judgment practice in non-jury cases. The court also said the filings appeared to show disputes about important facts relevant to the constitutional analysis.
Judge Mary Kay Vyskocil denied all pending summary-judgment motions without prejudice. She provisionally granted a pending motion to seal and ordered the parties to appear for a conference on April 2, 2025, to discuss settlement, the case’s status, and trial.
The detailed version
- Greater Chautauqua Federal Credit Union v. Quattrone · No. 1:22-cv-02753
- Vyskocil
- Mar. 24, 2025
Background
Greater Chautauqua Federal Credit Union, Boulevard Federal Credit Union, and Greater Niagara Federal Credit Union brought the action individually and on behalf of others similarly situated. They challenge the retroactive application of the Fair Consumer Judgment Interest Act, which reduced the statutory default post-judgment interest rate on state-court judgments involving consumer debts from nine percent to two percent. The credit unions claim that applying the Act retroactively is unconstitutional as applied to them.
The amended complaint names Sheriff James B. Quattrone, Sheriff John C. Garcia, Sheriff Michael J. Filicetti, and Attorney General Letitia James, each in an official capacity. The Sheriff Defendants, the Attorney General, and the Plaintiffs each filed a motion for summary judgment.
Court’s reasoning
The court’s individual practice rules state that there will not be summary-judgment practice in a non-jury case. The Plaintiffs initially demanded a jury trial but later withdrew that demand. The court therefore concluded that the pending summary-judgment motions did not comply with that rule.
The court also stated that a preliminary review of the parties’ factual statements, responses, and briefs appeared to show disputes about material facts concerning the relevant factors under Penn Central Transportation Co. v. City of New York. On summary judgment, a court may not decide which witnesses are credible or weigh disputed evidence. The court did not decide the constitutional challenge.
Ruling and next steps
The court denied without prejudice the pending motions for summary judgment filed by the Sheriff Defendants, the Attorney General, and the Plaintiffs. The court provisionally granted the motion to seal pending at ECF No. 176 and directed the clerk to terminate the motions listed at ECF Nos. 176, 180, 183, and 188. The parties were ordered to appear for a conference on April 2, 2025, to discuss settlement efforts, the status of the case, and trial.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.