United States District Court, N.D. New York
MANFREDI LAW GROUP, PLLC, JOHN S. MANFREDI, ESQ., New York, NY, Attorneys for Plaintiff.
OFFICE MARY JANE MURPHY, MARY JANE MURPHY, ESQ., Binghamton, NY, Attorneys for Defendant.
MEMORANDUM-DECISION and ORDER
DAVID N. HURD, District Judge.
On June 10, 2014, the United States of America (the "Government") filed this action against defendant Debra J. Chapman ("Chapman" or "defendant"), seeking to recover the outstanding debt allegedly owed on a defaulted federal student loan. The Government has moved for summary judgment pursuant to Federal Rule of Civil Procedure ("Rule") 56. Defendant opposes. The motion was considered on the basis of its submissions without oral argument.
On April 10, 2000, Chapman allegedly executed a promissory note to secure a federal student loan to finance her daughter's education at the Ridley-Lowell School of Business in Binghamton, New York. Gov.'s Mem. Supp. Summ. J., Ex. A, ECF No. 8-1 ("Promissory Note"). Defendant allegedly defaulted on this loan obligation on April 3, 2002. See Gov.'s Mem. Supp. Summ. J., Ex. B, ECF No. 8-2. According to a Certificate of Indebtedness ("COI") submitted by the Government and signed by a U.S. Department of Education Loan Analyst on May 21, 2014, defendant owes $2, 895.99 in principal and interest, with interest accruing at $0.17 per day thereafter. Id.
A. Motion for Summary Judgment - Legal Standard
The entry of summary judgment is warranted when "the pleadings, depositions, answers to interrogatories, and admissions on file, together with the affidavits, if any, show that there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law." Celotex Corp. v. Catrett , 477 U.S. 317, 322 (1986) (citing FED. R. CIV. P. 56(c)); see also Anderson v. Liberty Lobby, Inc. , 477 U.S. 242, 247 (1986). A fact is "material" for purposes of this inquiry if it "might affect the outcome of the suit under the governing law." Anderson , 477 U.S. at 248; see also Jeffreys v. City of N.Y. , 426 F.3d 549, 553 (2d Cir. 2005). A material fact is genuinely in dispute "if the evidence is such that a reasonable jury could return a verdict for the nonmoving party." Anderson , 477 U.S. at 248.
When deciding a summary judgment motion, a court must resolve any ambiguities and draw all inferences from the facts in a light most favorable to the non-moving party. Jeffreys , 426 F.3d at 553. Summary judgment is inappropriate where "review of the record reveals sufficient evidence for a rational trier of fact to find in the [non-movant's] favor." Treglia v. Town of Manlius , 313 F.3d 713, 719 (2d Cir. 2002) (citations omitted); see also Anderson , 477 U.S. at 250 (summary judgment is appropriate only when "there can be but one reasonable conclusion as to the verdict").
B. Statute of Limitations and Laches
As an initial matter, Chapman asserts that the statute of limitations on this alleged debt has run; alternatively, she maintains that the equitable defense of laches applies to bar the Government's recovery. Def.'s Opp'n Mem. 1-2. The Government responds that Congress eliminated all statutes of limitation, as well as the defense of laches, on actions to collect defaulted federal student loan debt. Gov.'s Mem. ¶¶ 23-35.
The Government is correct on both points. "The Higher Education Technical Amendments of 1991 ("HETA")... eliminates any applicable statutes of limitation in student loans cases." United States v. Pelt, 2013 WL 1173898, at *5 (E.D.N.Y. Mar. 18, 2013) (citation and explanatory parenthetical omitted). Likewise, "[v]irtually every Court that has addressed the issue has ruled that Congress also intended to eliminate the defense of laches in student loans cases." Id . (collecting cases); see also United States v. Husbands, 2012 WL 1714864, at *3 (E.D.N.Y. May 15, 2012) (finding that laches does not provide a defense for defaulted ...