Hampton v. Wells Fargo Bank, N.A.

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
KATRINA TOYA HAMPTON,
Plaintiff,
v.
WELLS FARGO BANK, N.A.
Defendant.
Case No. 25-cv-1935-ABA
MEMORANDUM OPINION
Plaintiff Katrina Toya Hampton has sued her creditor, Defendant Wells Fargo
Bank, N.A. (“Wells Fargo”), for $645,000 and the discharge of her mortgage
obligation to Wells Fargo, alleging breach of contract, promissory estoppel, and
unjust enrichment. She also seeks to quiet the title to the property at 10907 Marlboro
Crossing Court, Cheltenham, Maryland (the “Property”) and obtain a declaration that
she is the sole owner of the Property. Wells Fargo has filed a motion to dismiss. For
the reasons stated below, the Court will grant the motion to dismiss.
BACKGROUND
In 2012, Ms. Hampton obtained a mortgage loan from Wells Fargo for the
Property. Hampton v. Wells Fargo Bank N.A., Case No. 24-cv-00745-PX, 2025 WL
297849, at *1 (D. Md. Jan. 23, 2025); see also ECF No. 5-1 at 2. On two separate
occasions, Ms. Hampton “fell behind” on mortgage payments but reached a loan
modification agreement with Wells Fargo instead of proceeding with the respective
pending foreclosure actions. Hampton, 2025 WL 297849 at *1. In 2024, Ms.
Hampton filed a civil action against Wells Fargo and its Chief Executive Officer,
contending that Wells Fargo “attempt[ed] to collect a debt by harassment, . . . use[d]
false, deceptive misleading, unfair or unconscionable means, . . . and attempt[ed] to
collect the debt without first ‘validating’ it in response to Hampton’s written
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requests.” Id. at *2. Ms. Hampton contended that these alleged claims amounted to
multiple violations of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
and the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq., and embezzlement, 18
U.S.C. § 641. Hampton, 2025 WL 297849, at *1. That case was dismissed on January
23, 2025 for lack of personal jurisdiction over the CEO of Wells Fargo, id. at *3, and
for Ms. Hampton’s failure to state a claim against Wells Fargo. Id. at *5.
In the present action, Ms. Hampton alleges receipt of a “Presentment,” or a
“pay off statement,” from Wells Fargo on March 24, 2025. The “Presentment”
allegedly demanded $595,526.94 in payment, related to the 2012 mortgage loan and
subsequent modifications for the Property. ECF No. 3 ¶¶ 6–7; ECF No. 3-1 at 11—14.
On March 25, 2025, Ms. Hampton, through a notary, sent to Wells Fargo what
she called a “Notice of Conditional Acceptance” (“Notice”) “in exchange for closure
and settlement” of an account ending in 6164. Id. at 2. The “account” number is
consistent with the loan number identified in the “Presentment.” Id. at 11. Through
this Notice, Ms. Hampton purported to authorize Wells Fargo “to facilitate the use of
[her] credit to this obligation.” Id. at 2. Ms. Hampton also stated that “Scott Bessent
[the Secretary of the Department of the Treasury] is also being notified” that she
intends to use her “credit” to settle the account ending in 6164. Id.
It is not clear to what “credit” Ms. Hampton was referring. She provided to
Wells Fargo what she purported was an authorization to the Department of Treasury
to make a withdrawal from her “UCC Contract Trust Account” through an
international bill of exchange (the “Bill of Exchange”), payable to Wells Fargo for
$595,526.94. Id. at 10. The Bill of Exchange, purported to be an “[o]bligation of the
United States,” supposedly served to render “[s]ettlement in [f]ull [s]atisfaction” to
close out the loan account. Id. Through these allegations, it appears that Ms.
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Hampton is espousing a version of the baseless “redemption” theory, which the
Court will discuss below.
The Notice stated that Wells Fargo’s failure to confirm or provide “notice of
dishonor” would serve as an agreement that Wells Fargo “collectively and severably”
owes Ms. Hampton $640,000 and that she “may take all necessary steps to secure
it’s [sic] claim to the debt owed to it and to collect.” Id. at 2. On April 7, 2025, Ms.
Hampton sent an additional notice and “Affect [sic] of Failure to Respond.” Id. at 7.
On April 21, 2025, in a “Certificate of Non-Response” Ms. Hampton alleged,
again through her notary, that Wells Fargo “dishonored” Ms. Hampton
through their non response [sic], and thereby agree that
Katrina-Toya: 	Hampton 	accepted 	the 	subject 	payoff
Statement 	(request), 	returned 	the 	payoff 	request,
exchanged 	her 	exemption 	for 	the 	discharge 	of 	the
associated loan, presented and [sic] authorization for use
of her credit to setoff the associated loan balance, included
processing instructions, included a statement of account
showing a zero balance, sent a letter of credit to the
Secretary of the United States Treasury Department.
Id. at 9.
The Certificate of Non-Response asserts that because of Wells Fargo’s silence
on the matter, the account is “settled and closed,” and that Wells Fargo has “no
capacity to pursue collection on said account, and that further pursuit of collection is
an agreement that Wells Fargo Bank N.A. collectively and severably owes KATRINA
T HAMPTON $640,000” for expenses and handling the “Presentment.” Id. With this
letter, Ms. Hampton produced a “Statement of Account,” dated March 25, 2025, with
a purported balance of zero dollars. According to that document, a failure to correct
and return the Statement within two weeks “constitutes . . . agreement” with the
Statement. Id. at 15.
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There is nothing in the record to indicate that Ms. Hampton attempted to
satisfy this debt with anything other than through the purported “credit” described
above. In fact, in another letter dated April 22, 2025, Ms. Hampton stated that “the
narrow view that money is limited to legal tender is rejected” per § 1-201(24) of the
Uniform Commercial Code (UCC) and is not limited to United States currency. Id. at
19. Ms. Hampton articulated that Wells Fargo “cannot mandate that [she] fulfill any
debt using a specific form of currency or cash,” and that Wells Fargo’s inaction cured
any defects. Id.
In the instant Complaint filed in state court in 2025, Ms. Hampton claims
that, as a result of the actions described above, Wells Fargo (1) has been unjustly
enriched at her expense, (2) breached a tacit agreement to respond or negotiate in
good faith, (3) breached a promise to engage in resolution discussions to the
detriment of Ms. Hampton, and (4) violated the doctrine of promissory estoppel for
failing to resolve the issue. ECF No. 3 ¶¶ 15–18. In addition to $645,000, Ms.
Hampton is seeking various equitable remedies, including discharge from her
mortgage obligation and an order quieting title to the Property. Id. ¶¶ 22–32. On
June 17, 2025, Wells Fargo removed the case to this Court based on diversity
jurisdiction and then moved to dismiss. ECF Nos. 1 & 5. Ms. Hampton responded to
the motion and moved to remand, and Wells Fargo replied. ECF Nos. 7 & 8.
STANDARD OF REVIEW
A. 	Jurisdiction
Federal courts have limited jurisdiction and are “constrained to exercise only
the authority conferred by Article III of the Constitution and affirmatively granted by
federal statute.” In re Bulldog Trucking, Inc., 147 F.3d 347, 352 (4th Cir. 1998).
Accordingly, federal courts have original jurisdiction over civil cases, with some
exceptions that are not relevant here, in only two instances: (1) under federal
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question jurisdiction, where the case involves an issue of federal law, see 28 U.S.C. §
1331, or (2) under diversity jurisdiction where no defendant may be a citizen of the
same state as any plaintiff and the amount in controversy exceeds $75,000, see 28
U.S.C. § 1332. The Court has “an independent obligation to determine” the existence
of subject-matter jurisdiction. Hertz Corp. v. Friend, 559 U.S. 77, 94 (2010). As
stated, Wells Fargo removed this case based on diversity jurisdiction. ECF No. 1.
B. 	Stating a Claim
A complaint must contain “a short and plain statement of the claim showing
that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). When a defendant
asserts that, even assuming the truth of the alleged facts, the complaint fails to “state
a claim upon which relief can be granted,” the defendant may move to dismiss the
complaint. Fed. R. Civ. P. 12(b)(6). To withstand a motion to dismiss, the complaint’s
“[f]actual allegations must be enough to raise a right to relief above the speculative
level.” Bell Atl. Corp. v. Twombly, 550 U.S. 554, 555 (2007). The pleadings must
contain sufficient factual allegations to state a facially plausible claim for relief. Id. at
570. “A claim has facial plausibility when the plaintiff pleads factual content that
allows the court to draw the reasonable inference that the defendant is liable for the
misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). When considering
such a motion, the Court must “accept as true all of the factual allegations contained
in the complaint and draw all reasonable inferences in favor of the plaintiff.” King v.
Rubenstein, 825 F.3d 206, 212 (4th Cir. 2016).
DISCUSSION
A. 	Plaintiff’s Motion for Remand
A defendant may remove to federal court “any civil action brought in a State
court of which the district courts of the United States have original jurisdiction.” 28
U.S.C. § 1441. As previously stated, federal courts have original jurisdiction over civil
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cases where no defendant is a citizen of the same state as any plaintiff, and the
amount in controversy exceeds $75,000, see 28 U.S.C. § 1332. “Courts generally
determine the amount in controversy by reference to the plaintiff’s complaint.” JTH
Tax, Inc. v. Frashier, 624 F.3d 635, 638 (4th Cir. 2010); see also Wiggins v. N. Am.
Equitable Life Assurance Co., 644 F.2d 1014, 1016 (4th Cir. 1981) (The plaintiff’s
original claim is generally determinative of the jurisdictional amount, “provided that
the claim is made in good faith.”). “[E]vents occurring subsequent to removal which
reduce the amount recoverable, whether beyond the plaintiff’s control or the result of
[her] volition, do not oust the district court’s jurisdiction once it has attached.” St.
Paul Mercury Indem. Co. v. Red Cab Co., 303 U.S. 283, 293 (1938).
Ms. Hampton’s Motion to Remand to State Court, which is incorporated into
her response to the Motion to Dismiss, asserts that, because the amount in
controversy does not exceed $75,000, diversity jurisdiction under 28 U.S.C. § 1332 is
not satisfied. ECF No. 7 at 3. Instead, Ms. Hampton avers that she is seeking
“exclusively equitable relief,” id. at 1, despite “request[ing] the court to order
Defendant to pay the sum certain $645,000” in her Complaint, ECF No. 3 ¶ 25, and
elsewhere in accompanying documents. See ECF No. 3-1 at 2, 9, 17. With respect to
the citizenship of the parties, Ms. Hampton is a citizen of Maryland. ECF No. 3 at ¶ 2.
Wells Fargo, the only defendant in this case, is a citizen of South Dakota for purposes
of diversity jurisdiction. ECF No. 1 ¶ 5.
Notwithstanding Plaintiff’s later attempt to purely claim equitable relief, the
parties satisfy the amount in controversy and residency requirements of diversity
jurisdiction. Ms. Hampton seeks in the Complaint $645,000 in damages and the
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release of a $595,526.94 loan, and the parties are diverse. This Court has diversity
jurisdiction over Ms. Hampton’s claims.
B. 	Failure to State a Cognizable Claim
Through deciphering Ms. Hampton’s claims and asserted legal theories, it
appears that she advances a form of the meritless “redemption” theory. Proponents
of “redemption” theory falsely allege that they have a “monetary net worth” in an
account maintained by the U.S. Department of the Treasury. See Sovereign Citizens:
A Growing Domestic Threat to Law Enforcement, FBI Law Enforcement Bulletin
(Sep. 1, 2011), https://leb.fbi.gov/articles/featured-articles/sovereign-citizens-a-
growing-domestic-threat-to-law-enforcement. To access these funds and to pay
creditors, those who employ this “redemption” theory file “pseudo-legal document[s]
meant to serve as a repayment of debt.” J.M. Berger, Without Prejudice: What
Sovereign Citizens Believe, Geo. Wash. Program on Extremism (June 2016), at 6,
https://extremism.gwu.edu/sites/g/files/zaxdzs5746/files/downloads/JMB%20Sov
ereign%20Citizens.pdf. These “documents” may include UCC forms. FBI Law
Enforcement Bulletin, supra. Adherents to “redemption” theory believe that such
conduct “will compel the U.S. Treasury to fulfill [their] debts, such as credit card
debts, taxes, and mortgages.” Id.
Courts in this District and others have resoundingly rejected claims rooted in
“redemption” theory. Recently in Potter v. Verizon Communications, Inc., the
plaintiff had entered into a monthly contract with Verizon for phone and Internet
services and was seeking relief on the premise that, “because he paid for his monthly
phone and Internet services on credit, he is now a creditor of Verizon and that
Verizon is responsible for paying interest” to him. Potter v. Verizon Commc’ns Inc.,
Case No. 24-cv-1856-BAH, 2024 WL 3757901, at *1 (D. Md. Aug. 12, 2024). The
Court there recognized the advancement of “redemption” theory, and its frequent use
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in fraud schemes, noting that “[c]ourts around the country have repeatedly dismissed
as frivolous similar claims” and there was “no reason to deviate from the sound
reasoning of th[o]se cases” in dismissing Mr. Potter’s complaint. Id. at *2 (collecting
cases).
The Court of Appeals for the Fourth Circuit has not yet addressed this issue,
but the Third Circuit has in Miller v. Peco Exelon. There, Mr. Miller “complain[ed]
primarily that the named Defendants are liable to him because they refused to accept
‘Government Obligations Remittance Coupons’ he had prepared as ‘tender’ for
payment of his utility bills.” Miller v. PECO Exelon, 775 Fed. App’x 37, 37 (3rd Cir.
2019). The Third Circuit found Mr. Miller’s claims to be “baseless assertions,”
understanding Mr. Miller’s logic “to be based on . . . his understanding of the
Uniform Commercial Code and a belief that ‘there is no lawful money.’” Id. at 37—38.
Based on Ms. Hampton’s complaint and the accompanying documents, the
“redemption” theory is at the core of her claims. In response to what Ms. Hampton
describes as a “Presentment” from Wells Fargo detailing her mortgage loan valued at
$595,526.94, ECF No. 3-1 at 11—14, Ms. Hampton “enclose[d] an authorization . . .
to facilitate the use of [her] credit to this obligation.” Id. at 2 (emphases added). She
also informed Wells Fargo of a notice provided to Scott Bessent—the current
Secretary of the U.S. Department of the Treasury—of her use of “credit for this
purpose.” Id. To effect the use of this “credit,” Ms. Hampton claims she executed a
“bill of exchange” to compel the U.S. Department of the Treasury to withdraw funds
from her non-existent “UCC Contract Trust Account.” Id. at 5, 10.
Ms. Hampton does not allege that she used any form of legal tender to resolve
her debt with Wells Fargo. Her attempt to use a “UCC Contract Trust Account” is of
Ms. Hampton’s own creation, id. at 5 & 10, and it cannot be used to satisfy her
financial obligations. Archer v. Cabarrus County Courthouse, Case No. 24-cv-531,
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2025 WL 1103993, at *7—8 (M.D.N.C. Apr. 14, 2025) (declining to allow the use of
an alleged UCC Contract Trust Account to pay fines). Moreover, Ms. Hampton rejects
Wells Fargo’s mandate that she “fulfill her debts using a specific form of currency or
cash.” ECF No. 3-1 at 19.
There is plainly no legal basis for this theory. Ms. Hampton cannot merely
state that—because her “credit,” and no other legal tender, is being used to resolve
the Wells Fargo loan—her balance on that loan “is zero.” Id. at 2. Nor can she merely
state that Wells Fargo’s alleged failure to acknowledge her assertions to payment via
“credit” results in its own liability. Id. Ultimately, Ms. Hampton is attempting to
avoid paying her mortgage by using a “redemption” theory that has no legal or
factual basis and cannot prevail.
The Court turns now to address Ms. Hampton’s specific claims, which all lack
any valid legal basis.
1. 	Unjust Enrichment
Under Maryland law, a claim of unjust enrichment arises where “(1) the
plaintiff confers a benefit upon the defendant; (2) the defendant knows or
appreciates the benefit; and (3) defendant’s acceptance or retention of the benefit
under the circumstances is such that it would be inequitable to allow the defendant
to retain the benefit” without paying its value to the claimant. Benson v. State, 389
Md. 615, 651–52 (2005). Ms. Hampton alleges that “Defendant has been unjustly
enriched at [her] expense . . . as Defendant has retained benefits resulting from
Plaintiff’s actions without providing any compensation or lawful basis for [her]
demands.” ECF No. 3 ¶ 15. Ms. Hampton further alleges that she has “provided value
with the expectation of a lawful and equitable resolution, which was not
reciprocated” by Wells Fargo. Id. ¶ 16. But even accepting as true all of Ms.
Hampton’s factual allegations (as opposed to her legal conclusions), the complaint
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does not allege facts that would establish that Ms. Hampton has “confer[red] a
benefit upon” Wells Fargo by attempting to settle her mortgage debts with a fictitious
means of legal tender, or that Wells Fargo has been enriched by Ms. Hampton’s non-
payment of her obligations under the mortgage.
2. 	Breach of Contract
“A valid contract is formed by, among other elements, an offer and acceptance
and consideration.” Braude v. Robb, 255 Md. App. 383, 397 (2022). And under the
objective theory of contracts, which applies in Maryland, the terms of a contract
constitute the terms that “a reasonably prudent person in the same position would
have understood as to the meaning of the agreement.” Id. at 398 (citing Cochran v.
Norkunas, 398 Md. 1, 16 –17 (2007)) (internal quotations omitted).
Ms. Hampton alleges that “[u]pon the ‘Notarial Protest’ and Plaintiff’s
acceptance for value, a tacit agreement was formed under the assumption that
Defendant would act in good faith towards a resolution.” ECF No. 3 ¶ 17. She claims
that “Defendant’s failure to respond or negotiate constitutes a breach of this tacit
agreement, causing harm to Plaintiff.” Id. But the mortgage payment that Ms.
Hampton owes to Wells Fargo could not be paid through “credit” of Ms. Hampton’s
own creation. Ms. Hampton has not plausibly alleged that any “contract” was formed
through her alleged use of “credit” to satisfy her mortgage obligation. ECF No. 3-1 at
2; see Braude, 255 Md. App. at 397 (citing Chernick v. Chernick, 327 Md. 470, 479
(1992)).
3. 	Promissory Estoppel
To claim promissory estoppel, the plaintiff must show the existence of a
clear and definite promise; . . . where the promisor has a
reasonable expectation that the offer will induce action or
forbearance on the part of the promisee; 	. . . which does
induce actual and reasonable action or forbearance . . . and
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. . . causes a detriment which can only be avoided by the
enforcement of the promise.
McKenzie v. Comcast Cable Commc’ns, Inc., 393 F. Supp. 2d 362, 372–73 (D. Md.
2005) (citing Restatement (Second) of Contracts (1981) § 90(1)).
Ms. Hampton claims that “Defendant’s failure to engage in resolution
discussions, despite Plaintiff’s clear intentions and actions taken in reliance upon the
expected resolution process, has led to detriment.” ECF No. 3 ¶ 18. She further
alleges that she has “relied upon Defendant’s implied promise of negotiation and
resolution to [her] detriment.” Id. None of this constitutes an actionable claim for
promissory estoppel, among other reasons because the undisputed record establishes
that Wells Fargo has made multiple attempts to resolve disputes around Ms.
Hampton’s 2012 loan, see Hampton, 2025 WL 297849, at *1, and the March 24,
2025 “Presentment” was at least her third opportunity to pay it off.
CONCLUSION
Even accepting Ms. Hampton’s factual allegations as true, her core legal
theory—redemption theory—and her specific claims of unjust enrichment, breach of
contract, and promissory estoppel, do not state claims on which relief can be granted.
Ms. Hampton’s full obligation to pay her mortgage on the Property at issue remains.
Her claims will be dismissed with prejudice.
A separate order follows.
Date: March 4, 2026 	/s/
Adam B. Abelson
United States District Judge
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