坦普尔诉信安第一资本有限责任公司案

Pro se plaintiff Erica Davis Temple sued Reliance First Capital LLC and Dovenmuehle Mortgage, Inc. for violations of the Real Estate Settlement Procedures Act (RESPA), breach of mortgage agreement, and breach of covenants of good faith and fair dealing. The case was filed on May 20, 2024, in the U.S. District Court for the Northern District of Alabama. Defendants moved to dismiss, and the court converted the motion to summary judgment. On June 4, 2025, Judge Annemarie Carney Axon granted summary judgment for defendants on the RESPA claims and declined supplemental jurisdiction over state law claims, dismissing them without prejudice. Temple appealed to the Eleventh Circuit on June 16, 2025.

On June 4, 2025, the district court granted summary judgment in favor of defendants on all RESPA claims, dismissed state law claims without prejudice, and denied all pending motions including sanctions, injunctive relief, and leave to amend. Plaintiff filed a notice of appeal to the Eleventh Circuit on June 16, 2025.

Whether defendants violated RESPA's requirements for responding to and reasonably investigating borrower inquiries; whether defendants breached the mortgage agreement and the covenants of good faith and fair dealing; and whether the court should exercise supplemental jurisdiction over state law claims after dismissing the federal claims.

This case highlights the challenges faced by pro se litigants in complex federal regulatory claims under RESPA. The decision reinforces that plaintiffs must present sufficient evidence to survive summary judgment on RESPA claims. The case also demonstrates judicial efficiency in converting motions to dismiss to summary judgment when parties attach extrinsic evidence. The ongoing appeal to the Eleventh Circuit indicates continued legal scrutiny of mortgage servicer obligations under federal consumer protection laws.