HARRISON v. WELLS FARGO BANK (2021)

United States Court of Appeals, Ninth Circuit.2021-07-22No. No. 20-15493

Summary · law.co

Holding. The appellate court affirmed the district court's summary judgment, concluding that Harrison failed to establish a genuine dispute of material fact regarding her loan qualification or the pretext behind Wells Fargo's denial decision.

Patrina Harrison appealed a district court's grant of summary judgment in her lawsuit against Wells Fargo, in which she claimed racial discrimination in lending under federal civil rights statutes and consumer credit laws. The appellate court reviewed the case without deference to the lower court's legal conclusions and determined that Harrison had not presented sufficient evidence to create a factual dispute about either her qualification for the loan or whether Wells Fargo's stated reason for denying her application was a cover for discriminatory intent. Because the record lacked material facts supporting her discrimination claims, the summary judgment was properly entered in Wells Fargo's favor.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

Whether summary judgment was appropriate in a lending discrimination case
Whether plaintiff presented evidence of loan qualification and pretext
Application of burden-shifting framework in ECOA, FHA, and § 1981 claims

Procedural posture

Harrison appealed pro se from summary judgment entered by the district court in favor of Wells Fargo on her discrimination claims.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion · public domain

MEMORANDUM **

Patrina Harrison appeals pro se from the district courts summary judgment in her action alleging racial discrimination claims under 42 U.S.C. §§ 1981, 1982, the Equal Credit Opportunity Act (“ECOA”), and the Fair Housing Act (“FHA”). We have jurisdiction under 28 U.S.C. § 1291. We review de novo. Lindsey v. SLT L.A., LLC, 447 F.3d 1138, 1144 (9th Cir. 2006). We affirm.

The district court properly granted summary judgment because Harrison failed to raise a genuine dispute of material fact as to whether she was qualified for the loan she sought from defendant Wells Fargo or whether Wells Fargos reason for denying her loan application was pretextual. See 15 U.S.C. § 1691(a)(1) (providing that under ECOA it is unlawful “for any creditor to discriminate against any applicant, with respect to any aspect of a credit transaction ․ on the basis of race, color ․”); Sanghvi v. City of Claremont, 328 F.3d 532, 536 n.3 (9th Cir. 2003) (noting that burden-shifting framework under McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973), is applicable to FHA and § 1981 claims); Phiffer v. Proud Parrot Motor Hotel, Inc., 648 F.2d 548, 551 (9th Cir. 1980) (plaintiff asserting a § 1981 claim must prove she is qualified for the loan sought).

AFFIRMED.