Hotard v. Pennymac Loan Services, LLC

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
JARED HOTARD 	CIVIL ACTION
VERSUS 	NO: 25-1634
PENNYMAC LOAN SERVICES, LLC 	SECTION: “H”
ORDER & REASONS
Before the Court is Defendant PennyMac Loan Services, LLC’s Motion
to Dismiss (Doc. 36). For the following reasons, the Motion is GRANTED.
BACKGROUND
Plaintiff Jared Hotard brought this action in the 40th Judicial District
Court for the Parish of St. John against his mortgage holder, Defendant
Pennymac Loan Services, LLC. Plaintiff is the owner of property located at
3508 Main Street, LaPlace, Louisiana. Plaintiff alleges that his property
sustained damage during Hurricane Ida and a subsequent fire, and Plaintiff
filed a claim with his insurer. His insurer was later placed into receivership
and the Louisiana Insurance Guaranty Association became responsible for
Plaintiff’s insurance claims. Plaintiff and the Louisiana Insurance Guaranty
Association settled his claims, and Defendant, as mortgagee on the property,
was included as an additional payee on the settlement checks. Plaintiff alleges
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that Defendant refused to release the funds owed to Plaintiff to reimburse him
for repairs to his home for three months. Plaintiff alleges that when Defendant
ultimately released the funds, it failed to pay Plaintiff interest on those
amounts as required by Louisiana Revised Statutes § 6:337. Plaintiff brings
claims for monetary and injunctive relief for Defendant’s violation of § 6:337.
Plaintiff also asserts class action allegations.
Defendant has moved to dismiss Plaintiff’s claims, arguing that he lacks
standing and that § 6:337 does not provide a private right of action. Plaintiff
opposes. The Court held oral argument on this Motion on May 7, 2026.
LEGAL STANDARD
Defendant moves to dismiss Plaintiff’s claim under both Federal Rule of
Civil Procedure 12(b)(1) and (6). A Rule 12(b)(1) motion challenges the subject
matter jurisdiction of a federal district court. “A case is properly dismissed for
lack of subject matter jurisdiction when the court lacks the statutory or
constitutional power to adjudicate the case.”1 In ruling on a Rule 12(b)(1)
motion to dismiss, the court may rely on (1) the complaint alone, presuming
the allegations to be true, (2) the complaint supplemented by undisputed facts,
or (3) the complaint supplemented by undisputed facts and by the court's
resolution of disputed facts.2 The proponent of federal court jurisdiction—in
this 	case, 	the 	Plaintiff—bears 	the 	burden 	of 	establishing 	subject 	matter
jurisdiction.3
1 Home Builders Ass’n of Miss., Inc. v. City of Madison, 143 F.3d 1006, 1010 (5th Cir.
1998). 2 Den Norske Stats Oljesels kap As v. Heere MacVof, 241 F.3d 420, 424 (5th Cir. 2001).
3 See Physicians Hosps. of Am. v. Sebelius, 691 F.3d 649, 652 (5th Cir. 2012).
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To survive a Rule 12(b)(6) motion to dismiss, a plaintiff must plead
enough facts “to state a claim for relief that is plausible on its face.”4 A claim is
“plausible on its face” when the pleaded facts allow the court to “draw the
reasonable inference that the defendant is liable for the misconduct alleged.”5
A court must accept the complaint’s factual allegations as true and must “draw
all reasonable inferences in the plaintiff’s favor.”6 The court need not, however,
accept as true legal conclusions couched as factual allegations.7 To be legally
sufficient, a complaint must establish more than a “sheer possibility” that the
plaintiff’s claims are true.8 If it is apparent from the face of the complaint that
an insurmountable bar to relief exists and the plaintiff is not entitled to relief,
the 	court 	must 	dismiss 	the 	claim.9 The 	court’s 	review 	is 	limited 	to 	the
complaint and any documents attached to the motion to dismiss that are
central to the claim and referenced by the complaint.10
LAW AND ANALYSIS
Defendant moves to dismiss Plaintiff’s claim that Defendant failed to pay
him interest on insurance settlement proceeds in compliance with Louisiana
Revised Statutes § 6:337 for two reasons: (1) Plaintiff lacks standing, and (2) §
4 Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550
U.S. 544, 547 (2007)).
5 Id.
6 Lormand v. U.S. Unwired, Inc., 565 F.3d 228, 232 (5th Cir. 2009).
7 Iqbal, 556 U.S. at 678.
8 Id.
9 Lormand, 565 F.3d at 255–57.
10 Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 498 (5th Cir. 2000).
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6:337 does not provide a private right of action. This Court will consider each
argument in turn.
A. Standing
Defendant argues that Plaintiff does not have Article III standing to
bring his claims for either monetary or injunctive relief. Defendant argues that
Plaintiff lacks standing to bring a monetary claim because he did receive
interest, and he lacks standing to bring a claim for injunctive relief because
there is no threat of future injury. Defendant asks this Court to dismiss
Plaintiff’s case for lack of subject matter jurisdiction.
“It is well settled that unless a plaintiff has standing, a federal district
court lacks subject matter jurisdiction to address the merits of the case.”11
“Courts may dismiss for lack of subject matter jurisdiction on any one of three
different bases: (1) the complaint alone; (2) the complaint supplemented by
undisputed 	facts 	in 	the 	record; 	or 	(3) 	the 	complaint 	supplemented 	by
undisputed facts plus the court’s resolution of disputed facts.”12 “A motion to
dismiss for lack of standing may be either facial or factual.”13 Where, as here,
the Defendant has made a factual attack challenging the existence of subject
matter 	jurisdiction, 	irrespective 	of 	the 	pleadings, 	“matters 	outside 	the
pleadings, such as testimony and affidavits are considered.”14
11 Matte v. Sunshine Mobile Homes, Inc., 270 F. Supp. 2d 805, 813 (W.D. La. 2003).
12 Clark v. Tarrant Cnty., 798 F.2d 736, 741 (5th Cir. 1986).
13 Superior MRI Servs., Inc. v. All. Healthcare Servs., Inc., 778 F.3d 502, 504 (5th Cir.
2015). 14 Norwood v. United Med. Recovery, LLC, No. 4:21-CV-134-DMB-JMV, 2022 WL
4088081, at *1 (N.D. Miss. Sept. 6, 2022).
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a. Monetary Relief
Defendant argues that Plaintiff has no Article III standing to bring a
monetary 	claim 	for 	relief 	because 	he 	received 	interest 	on 	the 	insurance
settlement proceeds at issue. Standing under Article III requires a plaintiff to
“demonstrate a ‘personal stake’ in the suit.”15 To establish such a personal
stake for purposes of Article III, a plaintiff must show three elements: (1) an
“injury in fact” that is “concrete and particularized” and “actual or imminent”;
(2) a “causal connection between the injury and the conduct complained of”;
and (3) a likelihood, as opposed to mere speculation, that a favorable decision
will redress the injury.16 “When considering whether a plaintiff has Article III
standing, a federal court must assume arguendo the merits of his or her legal
claim.”17
Defendant argues that Plaintiff has not established an injury in fact. In
support, Defendant points to a check for $2.05 in interest sent to Plaintiff on
July 5, 2025. Defendant argues that Plaintiff has no standing to assert a claim
for nonpayment of interest because he received the $2.05 interest payment. In
response, Plaintiff does not contest that the $2.05 check was a payment of
interest. Rather, he argues that $2.05 is far less than the interest he is owed
and is based on a .01% interest rate, which is not in compliance with Louisiana
Revised 	Statutes 	§ 	6:337. 	Defendant 	correctly 	points 	out, 	however, 	that
Plaintiff’s Complaint states only that he did not receive interest, not that the
15 Camreta v. Greene, 563 U.S. 692, 701 (2011) (quoting Summers v. Earth Island
Institute, 555 U.S. 488, 493 (2009)).
16 Lujan v. Defs. of Wildlife, 504 U.S. 555, 560-61 (1992) (internal quotations omitted).
17 N. Cypress Med. Ctr. Operating Co. v. Cigna Healthcare, 781 F.3d 182, 191 (5th
Cir. 2015) (quoting Cole v. Gen. Motors Corp., 484 F.3d 717, 723 (5th Cir. 2007)) (citation
modified).
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interest amount paid was insufficient. Therefore, Defendant is correct that
Plaintiff’s Complaint does not establish standing for monetary relief, and
dismissal for lack of subject matter jurisdiction is appropriate.18
Plaintiff’s 	pleading 	deficiency, 	however, 	is 	easily 	remedied 	by 	an
amendment to his Complaint. If Plaintiff alleges the interest payment was
insufficient, he will have stated an injury in fact. Rule 15 requires that leave
to amend be freely given when justice so requires. Accordingly, Plaintiff may
amend his Complaint in order to properly allege standing.
b. Injunctive Relief
As to the injunctive relief requested by Plaintiff—an order preventing
Defendant from failing to pay interest on insurance settlement proceeds—
Defendant argues that Plaintiff does not have standing for the injunctive relief
requested because he paid off his mortgage in August 2025, and therefore there
is no risk of future harm. Indeed, when a plaintiff seeks injunctive relief, he
must show “a real and immediate threat of future or continuing injury apart
from any past injury.”19
Plaintiff does not directly address this argument. Instead, he argues
that even assuming that he does not personally have standing for injunctive
18 Plaintiff also argues that the voluntary cessation doctrine prevents Defendant from
arguing that the case is moot because the $2.05 interest payment was made after Plaintiff
filed his lawsuit. “The doctrine of voluntary cessation evaluates the risk that a defendant is
engaging in ‘litigation posturing’ to avoid judicial review. Accordingly, it must be ‘absolutely
clear’ that the defendant's challenged conduct ‘could not reasonably be expected to recur’ to
divest” the court of jurisdiction. U.S. Navy SEALs 1-26 v. Biden, 72 F.4th 666, 673 (5th Cir.
2023) (internal quotations omitted). As discussed in the next section, Defendant’s conduct
cannot be expected to recur, and therefore the doctrine of voluntary cessation does not apply
to prevent dismissal for lack of standing.
19 Aransas Project v. Shaw, 775 F.3d 641, 648 (5th Cir. 2014) (citing In re Stewart, 647
F.3d 553, 557 (5th Cir. 2011)).
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relief, the other class members do. He argues that courts sometimes recognize
standing to seek relief on behalf of class members even where the named
plaintiff’s claim is moot. The cases Plaintiff cites in support of this proposition,
however, are easily distinguishable because they involve cases in which a class
is already certified or a class certification motion is pending.20 In Zeidman v.
J. Ray McDermott & Co., for example, the question before the court was
whether “a purported but uncertified class action” should be “dismissed for
mootness upon tender to the named plaintiffs of their personal claims, despite
the existence of a timely filed and diligently pursued pending motion for class
certification.”21 In considering this question, the Fifth Circuit acknowledged
that the general principle is “that a purported class action becomes moot when
the personal claims of all named plaintiffs are satisfied and no class has
properly been certified. In such a case there is no plaintiff (either named or
unnamed) who can assert a justiciable claim against any defendant and
consequently there is no longer a ‘case or controversy’ within the meaning of
Article III of the Constitution.”22 Accordingly, because a class has not been
certified, Plaintiff cannot rely on the claims of future possible class members
to establish standing for injunctive relief. Further, because he has paid off the
20 See Sosna v. Iowa, 419 U.S. 393, 399 (1975) (“If appellant had sued only on her own
behalf, both the fact that she now satisfies the one-year residency requirement and the fact
that she has obtained a divorce elsewhere would make this case moot and require dismissal.
But appellant brought this suit as a class action and sought to litigate the constitutionality
of the durational residency requirement in a representative capacity. When the District
Court certified the propriety of the class action, the class of unnamed persons described in
the certification acquired a legal status separate from the interest asserted by appellant. We
are of the view that this factor significantly affects the mootness determination.”).
21 651 F.2d 1030, 1041 (5th Cir. 1981).
22 Id.
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mortgage at issue, he cannot show a “real and immediate threat of future or
continuing injury apart from any past injury.”23 	Plaintiff therefore does not
have standing for the injunctive relief requested. Dismissal for lack of subject
matter jurisdiction is appropriate here as well. No leave to amend is granted
as amendment would be futile.24
B. Private Right of Action
Although the Court has already determined that dismissal for lack of
subject 	matter 	jurisdiction 	of 	Plaintiff’s 	claims 	for 	both 	monetary 	and
injunctive relief is appropriate, the Court has also stated its intention to allow
Plaintiff 	to 	amend 	his Complaint to 	allege 	standing as to his claim for
monetary 	relief. 	Accordingly, 	the 	Court 	will 	consider 	Defendant’s 	final
argument for dismissal as well.
Defendant argues that Plaintiff’s claim should be dismissed because
Louisiana Revised Statutes § 6:337 does not create a private right of action.
Section 6:337 outlines certain duties of mortgagees and servicers vis-à-vis
insurance settlement proceeds on residential properties, including that the
proceeds should be deposited into a segregated account, that they should be
promptly distributed under certain circumstances, and that they should accrue
interest.25 Section 6:337 also provides that the insurance commissioner can
23 Aransas Project, 775 F.3d at 648.
24 When denying a motion to amend, the court must have a “substantial reason”
considering such factors as “undue delay, bad faith or dilatory motive on the part of the
movant, repeated failures to cure deficiencies by amendments previously allowed, undue
prejudice to the opposing party . . . and futility of the amendment.” Marucci Sports, LLC v.
Nat’l Collegiate Athletic Ass'n, 751 F.3d 368, 378 (5th Cir. 2014) (citation modified). An
amendment is deemed to be futile if it would be dismissed under a Rule 12(b)(6) motion. Id.
25 LA. REV. S TAT. § 6:337.
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impose penalties for the violation of these duties.26 The statute is silent as to
any right of the borrower to bring a claim for violation of the duties established
therein. Defendant argues therefore that it does not provide a private right of
action and that if the legislature intended to create a private right of action, it
would have done so.
In response, Plaintiff relies on Anderson v. Ochsner Health in which the
Louisiana Supreme Court considered whether there was a private right of
action under the Balance Billing Act.27 There too, the statute was silent on the
existence of a private right of action, so the Court looked to legislative intent.28
The Balance Billing Act expressly provides that an insured who has been billed
in violation of the Act can file a complaint with the attorney general and
instructs that the attorney general “may pursue remedies.”29 The defendant
argued that the inclusion in the Balance Billing Act of an administrative
remedy precluded a private right of action.30 The Louisiana Supreme Court
disagreed.31 The Court found “an implied private right of action exists under
La. R.S. 22:1871, et seq. based on (1) the legislature’s failure to expressly
prohibit an individual remedy; (2) the legislative intent to protect consumers;
and (3) the constitutional right of access to the courts in order to seek personal
relief.”32 The Court found that “the legislature enacted this statutory scheme
26 Id. § 6:337(c)(4) (“The commissioner may impose civil money penalties of up to five
hundred dollars per day for each day that a mortgagee or mortgage servicer fails to comply
with the requirements of Paragraph (1) or (2) of this Subsection.”).
27 172 So. 3d 579 (La. 2014).
28 Id.
29 Id.
30 Id.
31 Id.
32 Id. at 586.
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with protection of the consumer in mind. Accordingly, it is difficult to envision
a 	law 	denying 	recourse 	to 	individuals 	when 	that 	law’s 	principle 	aim 	is
individual protection.”33 It held that the power granted to the attorney general
in the Act is discretionary and therefore “further evidences the existence of an
implied private right of action.”34 It noted that “[a] person’s individual right to
seek recourse for an alleged wrong should not depend on a governmental body's
decision to pursue the offender.”35
Plaintiff argues that this Court should reach the same result as in
Anderson. Here too, § 6:337 does not expressly prohibit a private right of action,
was enacted for the protection of 	residential 	borrowers 	whose insurance
settlements are sent to their mortgage servicers, and the power granted to the
insurance 	commissioner 	to 	impose 	penalties 	is 	permissive. 	Section 	6:337
provides only that the commissioner “may impose civil money penalties of up
to five hundred dollars per day for each day that a mortgagee or mortgage
servicer fails to comply with the requirements” of the statute. This Court
agrees that the analysis in Anderson is squarely on point with the question
presented here.
Defendant attempts to distinguish Anderson by pointing out that the
Balance 	Billing 	Act 	expressly 	incorporates 	the 	Louisiana 	Unfair 	Trade
Practices Act (“LUTPA”) as an enforcement mechanism. But this misconstrues
the Anderson Court’s opinion and the Act itself. LUTPA is incorporated into
the Balance Billing Act with respect to the attorney general’s enforcement
33 Id. at 584.
34 Id.
35 Id.
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rights.36 	The 	Louisiana 	Supreme 	Court 	simply 	observed 	that 	the 	Act’s
incorporation of LUTPA suggested the legislature’s intent to expose violators
to more liability, not less.37 The Court does not base its finding of a private
right of action on the Balance Billing Act’s incorporation of LUTPA. That said,
Defendant has failed to meaningfully distinguish the Louisiana Supreme
Court’s decision in Anderson.
For its part, Defendant relies on cases from this Court that found no
private right of action in the Louisiana Motor Vehicles Act (“LMVA”). For
example, in Crescent City M Dealership, L.L.C. v. Mazda Motor of America,
Inc., a section of this Court stated that “the grant of such broad regulatory and
enforcement powers to a state agency [in the LMVA] forecloses a private right
of action, absent language expressly granting one.”38 However, this case is
easily 	distinguishable 	where 	the 	LMVA 	provides 	a 	much 	more 	robust
enforcement scheme than is present here and the enforcement powers granted
by it to the state agency are not discretionary.39 Indeed, a court in the Western
36 LA. REV. S TAT. § 22:1877(A)(6) (“In the event that a contracted health care provider
fails to comply with a notice of unfair trade practices, the attorney general may proceed in
accordance with the Unfair Trade Practices and Consumer Protection Law, R.S. 51:1401 et
seq.”). 37 Anderson, 172 So. 3d at 584 (“The Balance Billing Act’s reference to and
incorporation of these Unfair Trade Practices and Consumer Protection provisions serve to
illustrate the legislature’s intention of exposing violators to more liability, not less.”).
38 Crescent City M Dealership, L.L.C. v. Mazda Motor of Am., Inc., No. CIV. A. 00-
1620, 2000 WL 1372965, at *2 (E.D. La. Sept. 22, 2000), aff’d, 275 F.3d 43 (5th Cir. 2001).
39 “The LMVA empowers only the LMVC to enforce the provisions of the Act. The
Commission has the power to grant, deny, and revoke licenses for motor vehicle dealerships,
to hold hearings, subpoena witnesses, impose civil penalties for violations of the Act, and
order renewal or reinstatement of a dealer's franchise that a manufacturer has canceled
without just cause. The Act also empowers the Commission to institute an injunctive action
to enforce its provisions, and to enter cease and desist orders prohibiting conduct in violation
of the Act. Thus, the LMVA constitutes a comprehensive regulatory scheme that confers upon
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District 	of 	Louisiana 	made 	the 	same 	distinction 	between 	Anderson 	and
Crescent City, stating that unlike the Balance Billing Act, “the LMVA creates
a comprehensive regulatory scheme and an administrative complaint process
that can be invoked by an aggrieved dealer.”40 Likewise, Defendant cites to
Stokes v. Southwest Airlines, in which the Fifth Circuit held that the Air
Carrier Access Act did not provide a private right of action where it created a
mandatory “comprehensive administrative scheme designed to vindicate fully
the rights of disabled persons.”41 The cases cited by Defendant, in addition to
being non-binding, involve robust and comprehensive administrative remedies
unlike the permissive enforcement powers granted by the Balance Billing Act
in Anderson or § 6:337 at issue here. This Court finds these cases easily
distinguishable,
This Court finds that in reliance on Anderson, § 6:337 creates a private
right of action based on “(1) the legislature’s failure to expressly prohibit an
individual remedy; (2) the legislative intent to protect consumers; and (3) the
constitutional right of access to the courts in order to seek personal relief.”42
The Court finds compelling the fact that the remedy created by § 6:337 provides
the Commission the power and authority to implement its purpose.” Id.; LA. REV. S TAT. §
32:1259 (“If it appears to the commission at any time that a person is violating the provisions
of this Chapter or any rule or order of the commission issued pursuant to this Chapter, it
shall notify the person engaged in such conduct to appear and show cause why a cease and
desist order should not be issued prohibiting the proscribed conduct.”).
40 Navarre Chevrolet, Inc. v. Hyundai Motor Am. Corp., No. 2:18-CV-0327, 2019 WL
2166679, at *3 (W.D. La. Feb. 4, 2019).
41 887 F.3d 199, 202–03 (5th Cir. 2018). (“If, after an investigation and hearing, the
DOT finds an ACAA violation, it must issue an order compelling compliance, id. § 46101(a)(4),
and may further revoke the airline’s air carrier certificate, id. § 41110(a)(2)(B), or impose
civil penalties of up to $25,000 for each act of discrimination.”).
42 Anderson, 172 So. 3d at 586.
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no recourse to a borrower whose mortgage servicer violates its provisions. The
statute 	provides 	only 	for 	a 	penalty 	to 	be 	imposed 	by 	the 	insurance
commissioner.43 There is no process outlined for an aggrieved borrower to
complain to the insurance commissioner, and there is no indication that any
amount of the penalty will be distributed to the borrower to make him whole.
Just as in Anderson, the commissioner is “seeking to obtain relief that will not
directly 	benefit 	the 	plaintiff.”44 	Further, 	the 	commissioner 	is 	under 	no
obligation to impose a penalty for violations of § 6:337. “A person’s individual
right 	to 	seek 	recourse 	for 	an 	alleged 	wrong 	should 	not 	depend 	on 	a
governmental body’s decision to pursue the offender.”45 Finally, the text of the
statute makes clear that it was enacted “with protection of the consumer in
mind.”46 The statute imposes duties on mortgagees or mortgage servicers
servicing residential mortgage loans relative to the disbursement of insurance
proceeds and seeks:
to provide for prompt endorsement; to require prompt payment to
borrower-payees in certain circumstances; to require placement of
settlement 	proceeds 	in 	a 	segregated 	account; 	to 	provide 	for
requirements for a residential mortgagee or mortgage servicer; to
provide for the payment of proceeds relative to additional living
expenses 	and 	contents 	insurance; 	to 	provide 	for 	notice 	by 	a
mortgagee 	or 	mortgage 	servicer 	in 	certain 	circumstances; 	to
provide for the release of proceeds held by a mortgagee or mortgage
servicer; to provide for civil money penalties; to provide for the
payment of interest accrued on settlement proceeds; to provide for
43 LA. REV. S TAT. § 6:337(c)(4) (“The commissioner may impose civil money penalties
of up to five hundred dollars per day for each day that a mortgagee or mortgage servicer
fails to comply with the requirements of Paragraph (1) or (2) of this Subsection.”).
44 Anderson, 172 So. 3d at 584.
45 Id.
46 Id.
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release 	of 	excess 	funds 	upon 	written 	request; 	to 	provide 	for
applicability; and to provide for related matters.47
This Court therefore finds that § 6:337 creates “an implied right of action based
on the legislative purpose and the spirit of the law.”48
CONCLUSION
For the foregoing reasons, the Motion to Dismiss is GRANTED for lack
of subject matter jurisdiction. IT IS FURTHER ORDERED that Plaintiff
may amend his Complaint within 20 days of this Order to the extent that he
can allege standing. Failure to amend will result in dismissal.
New Orleans, Louisiana this 18th day of May, 2026.
____________________________________
JANE TRICHE MILAZZO
UNITED STATES DISTRICT JUDGE
47 Louisiana House Journal, 2022 Reg. Sess. No. 44 (House Bill No. 1064).
48 Id. at 585.
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