In Williams v. PennyMac Loan Services, LLC, the Middle District of North Carolina once again refused to let a mortgage servicer wriggle out of Pay-to-Pay fee litigation at the pleading stage. The Court denied PennyMac’s Rule 12(b)(6) motion in a detailed opinion that should feel very familiar to anyone who has been watching this line of cases develop since Alexander v. Carrington and, closer to home, Custer v. Dovenmuehle.

The Chapter 7 case of James and Sharon Bryant and the related adversary proceeding brought by Eastwood Construction Partners, LLC is not notable because it breaks new doctrinal ground. It is notable because it shows—almost clinically—how civil litigation spillover, aggressive creditor strategy, and pro se overconfidence (amplified by generative AI) can collide inside a consumer bankruptcy case.

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In a detailed but pragmatic opinion, Chief Judge Catherine Eagles offers a tidy roadmap for mortgage-servicing litigation in the Middle District — clarifying what sticks at the pleading stage (loss-mitigation fee violations, RESPA damages, UDTPA claims) and what gets tossed to the curb (negligence, joint venture fantasies, and the perennial “they threatened foreclosure!” count that courts treat like the boy who cried wolf).

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In In re Lombrano, Judge Kahn confronted the all-too-common BAPCPA problem of repeat filings colliding head-on with the automatic stay provisions. Ms. Lombrano—pro se—had filed three bankruptcy cases in under five months, two Chapter 7s (one dismissed for filing defects and jurisdictional issues, the next for nonpayment of the fee) followed by this Chapter 13.

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In In re Peters, Judge Kahn addressed a  recurring question: when Chapter 13 debtors propose to pay unsecured claims in full under §1325(b)(1)(A), must those creditors also receive post-petition interest?

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Judge Schroeder’s September 30, 2025 portrait of  the property report as a  CRA  in Joyce v. First American Mortgage Solutions, LLC (No. 1:23-cv-1069) denied the defendant’s motion for judgment on the pleadings, allowing a Fair Credit Reporting Act (“FCRA”) claim to proceed where a “Property Report” combined another consumer’s judgments with the plaintiff’s file and was then used by a lender to deny him a loan.

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In this sequel to Keller v. Experian I, 2024 WL 1349607 (M.D.N.C. Mar. 30, 2024), Judge Thomas Schroeder once again dismissed Eric Keller’s Fair Credit Reporting Act (FCRA) suit against Experian—this time for lack of Article III standing rather than for failure to state a claim.

Background

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When a repossession turns into a shouting match—or worse, when the debtor is still inside the car—any lawyer who’s ever seen the phrase “without breach of the peace” in N.C. Gen. Stat. § 25-9-609 should immediately start thinking “state-court claim and delivery,” not “self-help.”

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