Unreported / Non-Citable
Background
Elisabeth Haby financed a $4,800 spa treatment through GreenSky under a promotion promising no interest if the balance was paid within 12 months. She activated autopay and selected a “statement balance” option, but the parties disputed what that label communicated and whether the payment setup would retire the promotional balance before interest accrued.
Haby alleged that GreenSky’s online interface and loan administration were misleading and caused financial and emotional harm. GreenSky sought summary judgment, arguing that the contract and account records defeated her claims, and both sides filed evidentiary motions directed at declarations and testimony.
The Court’s Holding
The court denied GreenSky’s summary-judgment motion because material factual disputes required a jury’s assessment. The record permitted competing interpretations of what the account interface represented, what Haby reasonably understood, and whether the challenged practices caused actionable injury. At this stage the court was required to draw reasonable inferences for Haby rather than resolve credibility or choose among competing evidence.
The court also declined to strike the declarations offered by Haby and her mother. A party’s own testimony can support emotional-distress damages, and their descriptions of anxiety, frustration, anger, sleeplessness, and nervousness were sufficient to create a triable issue. Haby’s separate motion to strike was denied as moot.
Key Takeaways
- Interface labels such as “statement balance” can create fact questions when promotional financing terms make the practical meaning unclear.
- Summary judgment cannot resolve competing reasonable understandings of consumer-facing disclosures.
- A plaintiff’s testimony may establish emotional distress without medical evidence when it is sufficiently concrete.
- Courts generally evaluate declaration objections in context rather than striking an entire declaration for isolated argumentative statements.
Why It Matters
For California lenders and fintech platforms, the ruling is a reminder that technically accurate contract language may not eliminate risk created by payment interfaces and account workflows. Consumer counsel can also use detailed lay testimony to preserve noneconomic-damages issues for trial, although the ultimate credibility and amount remain for the factfinder.