Weulander v. North Star Credit Union

U.S. District Court, District of Minnesota

Weulander v. North Star Credit Union

Trial Court Opinion

                   UNITED STATES DISTRICT COURT                          
                      DISTRICT OF MINNESOTA                              
KATHY WEULANDER,                                                         
                                      Civil No. 23-885 (JRT/LIB)         
                       Plaintiff,                                        

v.                                                                       
                                   ORDER GRANTING IN PART AND            
NORTH STAR CREDIT UNION,           DENYING IN PART DEFENDANT’S           
                                        MOTION TO DISMISS                
                      Defendant.                                         

    Aaron  David  Sampsel,  Kristen  Williams,  Carl  E.  Christensen,  and  Ryan 
    Supple, CHRISTENSEN LAW OFFICE PLLC, 305 Fifth Avenue North, Suite 375, 
    Minneapolis, MN 55401, for Plaintiff.                                

    Andrew R. Shedlock, KUTAK ROCK LLP, 60 South Sixth Street, Suite 3400, 
    Minneapolis, MN 55402, for Defendant.                                


    This action arises out of Plaintiff Kathy Weulander’s allegations that Defendant 
North  Star  Credit  Union  (“NSCU”)  improperly  processed  68  unauthorized  electronic 
transactions by a third-party, which transferred $187,380 out of Weulander’s accounts 
over the span of approximately five weeks.  Weulander brings ten causes of action against 
NSCU, including violations of the Electronic Fund Transfers Act, three breach of contract 
claims, negligence, conversion, and aiding and abetting tortious conduct.  NSCU moves to 
dismiss five of the ten counts.  Because the independent duty rule bars Weulander’s 
negligence and conversion claims, the Court will grant NSCU’s motion to dismiss as to 
those claims.  And because Weulander has plausibly alleged her treble damages, breach 
of E-Commerce Policy, and aiding-and-abetting claims, the Court will allow those claims 
to proceed.                                                               

                          BACKGROUND                                     
I.   FACTS                                                                
    A.   Weulander’s Accountholder Agreement with NSCU                   
    Kathy Weulander is a long-time savings and checking account holder with NSCU.  
(Am. Compl. ¶¶ 15–16, June 8, 2016, Docket No. 16.)  When she opened her accounts, 

Weulander agreed to NSCU’s Membership and Account Agreement, which describes the 
terms and conditions of NSCU’s services.  (Id. ¶ 21.)  The agreement also incorporates 
NSCU’s Electronic Fund Transfers Agreement and Disclosure (“EFT Agreement”) and 
“Credit Union policies.”  (Id. ¶¶ 23, 134; see also Decl. of Jennifer Stedt (“Stedt Decl.”), ¶ 

4, Ex. C (“Membership and Account Agreement”) at 2, May 19, 2023, Docket No. 15.)1  
The  EFT  Agreement  outlines  Weulander’s  rights  and  responsibilities  concerning  the 
electronic fund transfer services offered by NSCU; it explains liability and establishes the 

proper protocol for handling unauthorized transactions.  (Am. Compl. ¶¶ 24–25; see also 
Stedt Decl. ¶ 3, Ex. B at 5.)                                             



    1 At the motion to dismiss stage, the Court may consider the allegations in the complaint 
as well as “those materials that are necessarily embraced by the pleadings.”  Schriener v. Quicken 
Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014).  The Court may consider exhibits attached to the 
pleadings  and  contract  documents,  so  long  as  those  documents  do  not  conflict  with  the 
complaint.  Porous Media Corp. v. Pall Corp., 
186 F.3d 1077, 1079
 (8th Cir. 1999); Stahl v. U.S. 
Dept. of Agric., 
327 F.3d 697, 700
 (8th Cir. 2003).                       
    Additionally, a  copy of NSCU’s E-Commerce Policy was enclosed  when NSCU 
provided Weulander with the Membership and Account Agreement.  (Am. Compl. ¶ 153.)  

The E-Commerce Policy requires NSCU “to always safeguard member data” and explains 
the different levels of protection NSCU provides to e-commerce activities.  (Decl. of 
Jennifer Stedt, ¶ 2, Ex. A at 3–6, June 13, 2023, Docket No. 20.)         

    B.   Unauthorized Electronic Transfers of Funds                      
    On  December  13,  2022,  Weulander  learned  of  unauthorized  activity  in  her 
accounts when a legitimate check she wrote was rejected due to insufficient funds.  (Am. 
Compl. ¶ 45.)  Weulander’s attorney-in-fact, Steve Jacobson, immediately contacted 
NSCU about the rejected check.  (Id. ¶¶ 4, 46.)  Weulander and Jacobson then discovered 

that  between  November  8  and  December  13,  2022,  a  total  of  $187,380  had  been 
transferred via electronic funds transfer (“EFT”) from Weulander’s accounts to another 
bank.  (Id. ¶¶ 36, 38.)  The funds were transferred through a series of 68 individual 

transactions—usually in increments of $3,000 and often with multiple transfers executed 
on the same day.  (Id. ¶ 36.)  The EFTs effectively depleted Weulander’s accounts.  (Id. ¶ 
37.)  Jacobson immediately notified NSCU that these transactions were not authorized by 
Weulander or himself.  (Id. ¶ 46.)                                        

    An unknown third party linked to an IP address in Indonesia was responsible for 
the unauthorized EFTs.  (Id. ¶ 33.)  The third party made multiple, incorrect password 
attempts  through  NSCU’s  online  banking  portal  before  finally  gaining  access  to 
Weulander’s accounts and resetting the password on November 3, 2022.  (Id. ¶ 31.)  After 
resetting the password, the third party logged into Weulander’s accounts 53 times over 
the course of four days.  (Id. ¶ 34.)  Then, the third party executed the 68 unauthorized 

EFTs from Weulander’s savings and checking accounts over the course of approximately 
five weeks.  (Id. ¶ 36.)                                                  
    Weulander  provided  written  notice  to  NSCU  of  the  unauthorized  EFTs  and 
demanded  a  full  accounting  and  explanation  of  NSCU’s  handling  of  the  EFTs,  in 

accordance with the parties’ agreement terms.  (Id. ¶¶ 49–50.)  Six days later, NSCU 
issued payments totaling $45,000 to Weulander’s savings account.  (Id. ¶ 51.)  Weulander 
promptly wrote again to NSCU to demand a full accounting and explanation of NSCU’s 

handling of the EFTs.  (Id. ¶ 52.)  NSCU never provided the results of any investigation that 
it may have conducted, nor did it respond to Weulander’s written notices concerning the 
unauthorized EFTs.  (Id. ¶¶ 91, 94.)                                      
    Weulander  subsequently  brought  this  action,  alleging  that  NSCU  improperly 

processed the 68 unauthorized EFTs and failed to follow investigation procedures after 
the fraudulent activity was reported, all in violation of federal law and the parties’ 
contract.  (Id. ¶¶ 2, 5–6.)  Weulander brings ten claims against NSCU, including for 
violations of the Electronic Fund Transfers Act (“EFTA”), breach of contract, negligence, 

conversion, and aiding and abetting tortious conduct.  (See id.)          
II.  PROCEDURAL HISTORY                                                   
    After NSCU filed a motion to dismiss Weulander’s original complaint for failure to 
state a claim, Weulander filed an amended complaint.  (See generally Def.’s Mot. Dismiss, 
May 18, 2023, Docket No. 9; Am. Compl.)  NSCU now moves to dismiss five of the ten 
counts in the amended complaint: (1) a claim for treble damages under the Electronic 

Fund Transfers Act; (2) breach of contract through violation of the E-Commerce Policy; (3) 
negligence; (4) conversion; and (5) aiding and abetting tortious conduct.  (Def.’s Renewed 
Mot. Dismiss, June 13, 2023, Docket No. 17.)                              

                           DISCUSSION                                    
I.   STANDARD OF REVIEW                                                   
    In reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the 
Court considers all facts alleged in the complaint as true to determine if the complaint 
states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009)).  “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.”  
Iqbal, 
556 U.S. at 678
.  The Court construes the complaint in the light most favorable to 

the plaintiff, drawing all inferences in the plaintiff’s favor.  Ashley Cnty. v. Pfizer, Inc., 
552 F.3d 659, 665
 (8th Cir. 2009).  But the Court is “not bound to accept as true a legal 
conclusion couched as a factual allegation.”  Papasan v. Allain, 
478 U.S. 265, 286
 (1986).  
A complaint need not have “detailed factual allegations” but must include more than 

conclusory statements or “a formulaic recitation of the elements” to meet the plausibility 
standard.  Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).          
II.  DEFENDANT’S MOTION TO DIMISS                                         
    Because Weulander’s negligence and conversion claims are precluded by the 

independent duty rule, the Court will grant NSCU’s motion with respect to those claims.  
The Court will deny the motion as to the remaining challenged claims.2    
    A.       Treble Damages Under the Electronic Fund Transfers Act      
    Weulander alleges NSCU violated various provisions of the EFTA, which establishes 

the  rights,  liabilities,  and  responsibilities  of  participants  in  electronic  fund  transfer 
activities.  See 
15 U.S.C. § 1693
, et seq.  In addition, Weulander alleges she is entitled to 
treble damages pursuant to section 1693f(e) of the EFTA.  NSCU does not challenge 
Weulander’s claims that it violated the EFTA; instead, it contends that Weulander has 

failed to state a claim for treble damages.                               
    Section 1693f allows a plaintiff to seek treble damages if a financial institution (1) 
fails to comply with certain investigation requirements before declining to provisionally 

credit  the  plaintiff  with  the  disputed  funds,  or  (2)  otherwise  acts  unreasonably  in 
determining whether the account charges were in error.  15 U.S.C. § 1693f(e).  Weulander 
alleges she is entitled to treble damages because NSCU did not make a good faith 




    2 As a threshold matter, the Court will deny NSCU’s first motion to dismiss as moot 
because Weulander filed an amended complaint in response.  See Cartier v. Wells Fargo Bank, 
N.A., 
547 F. App’x 800, 803
 (8th Cir. 2013) (“Some courts, as a matter of course, treat an amended 
complaint as mooting a pending motion to dismiss the original complaint.”).   
investigation or have a reasonable basis for believing that the EFTs were authorized based 
on evidence available at the time of any investigation performed.         

    The Court finds that Weulander has asserted allegations that support a plausible 
claim for treble damages.  The plausibility standard does not require highly detailed 
factual allegations, as NSCU appears to maintain.  See Twombly, 
550 U.S. at 555
.  Instead, 
a plaintiff must support her allegations with sufficient facts that allow the court to 

reasonably infer that the defendant is liable.  Iqbal, 
556 U.S. at 678
.  Here, Weulander 
alleges that NSCU did not provide her with information regarding any investigation (or 
even confirm that it conducted one) despite her requests; that NSCU did not recredit 

Weulander’s accounts for the full $187,380; and that 68 EFTs initiated by an Indonesian 
IP address, which nearly drained Weulander’s accounts, should have put NSCU on notice 
that the EFTs were likely fraudulent.  Weulander has pled sufficient facts to proceed with 
her treble damages claim.                                                 

    NSCU argues that Weulander fails to support her allegations that NSCU “knowingly 
and willfully” concluded that the EFTs were not in error or that NSCU failed to make a 
good faith investigation of the EFTs.3  But one of Weulander’s central allegations is that 



    3 NSCU also points to two cases where courts have dismissed claims for treble damages 
because the plaintiff failed to meet the plausibility standard.  But NSCU’s argument is unavailing, 
and the cases it cites are inapposite to this case.  See Mountcastle v. SunTrust Bank, No. 12-885, 
2013 WL 588981
, at *1, 4 (D. Md. Feb. 12, 2013) (plaintiff had knowledge of the financial 
institution’s investigation of the unauthorized activity, and he was primarily challenging the 
institution’s rejection of his claim for relief); Houston v. Fifth Third Bank, No. 18-5981, 2019 WL 
NSCU failed to provide her with any information about any investigation performed 
regarding the unauthorized EFTs.  Weulander could not provide more detailed factual 

allegations about NSCU’s investigation when she was never provided any documentation 
concerning that investigation to begin with.  The Court will not penalize Weulander for 
NSCU’s failures.  Weulander therefore has plausibly alleged a claim for treble damages 
under the EFTA.                                                           

    B.        Breach of Contract – E-Commerce Policy                     
    Weulander brings three breach of contract claims against NSCU.  Relevant to the 
instant  motion,  Weulander  alleges  NSCU  failed  to  implement,  utilize,  and  monitor 
appropriate  fraud  detection  safeguards  in  violation  of  its  E-Commerce  Policy.    In 

Minnesota, the elements for breach of contract are “(1) formation of a contract, (2) 
performance by plaintiff of any conditions precedent to his right to demand performance 
by the defendant, and (3) breach of the contract by defendant.”  Lyon Fin. Servs., Inc. v. 

Illinois Paper & Copier Co., 
848 N.W.2d 539, 543
 (Minn. 2014) (quotation omitted).  The 
only element NSCU challenges is the first one—that no contract was formed.  In support, 
NSCU argues that the E-Commerce Policy is not a contract that NSCU could breach 
because it is just a policy.  The Court disagrees.                        





1200574, at *1 (N.D. Ill. Mar. 14, 2019) (financial institution provided written documentation to 
the plaintiff concerning its investigation of the alleged unauthorized activity). 
    The  E-Commerce  Policy  is  incorporated  as  part  of  the  terms  of  the  parties’ 
contract.  The Membership and Account Agreement explicitly states that the parties 

agreed  to  the  terms  and  conditions  of  NSCU’s  “Credit  Union  policies,”  and  the  E-
Commerce Policy is one of the credit union’s policies.  (See Am. Compl. ¶ 23; Membership 
and Account Agreement at 2.)  Even though the E-Commerce Policy is not itself a separate 
contract, the Membership and Account Agreement encompasses the E-Commerce Policy 

as part of its terms and conditions.  Consequently, Weulander has plausibly alleged that 
NSCU breached the terms of the parties’ contract by failing to adhere to the E-Commerce 
Policy.                                                                   

    C.   Negligence                                                      
    The elements for negligence are (1) duty, (2) breach of the duty, (3) causation, and 
(4) damages.  Schweich v. Ziegler, Inc., 
463 N.W.2d 722, 729
 (Minn. 1990).  Weulander 
alleges that NSCU, as a professional credit union, owed a duty of care to safeguard her 

funds from unauthorized access by third parties and from unauthorized EFTs.  She 
maintains NSCU breached that duty in two ways: (1) by failing to exercise ordinary and 
reasonable care to safeguard Weulander’s accounts from unauthorized access by third 
parties; and (2) by failing to follow its own error resolution policies to implement security 

measures that would prevent unauthorized access or unauthorized EFTs.  NSCU counters 
that the negligence claim is precluded by the independent duty rule.      
    The independent duty rule provides that “when a contract defines a relationship 
between  two  parties,  a  plaintiff  is  not  entitled  to  recover  tort  damages  save  for 
exceptional cases in which a breach of contract ‘constitutes or is accompanied by an 
independent tort.’”  Blue Cross and Blue Shield of N.C. v. Rite Aid Corp., 
519 F. Supp. 3d 522
, 545 (D. Minn. 2021) (quoting Russo v. NCS Pearson, Inc., 
462 F. Supp. 2d 981, 994
 (D. 
Minn. 2006); Wild v. Rarig, 
234 N.W.2d 775, 789
 (Minn. 1975)).  Under the independent 
duty rule, the duty supporting a negligence claim must arise from something other than 
a contract between the parties; it must exist “without enforcement of the contract 

promise itself.”  U.S. Bank Nat’l Ass’n v. San Antonio Cash Network, 
252 F. Supp. 3d 714, 718
 (D. Minn. 2017) (quotation omitted).4                                 
    The Court finds that Weulander has not alleged an independent duty beyond that 

in the parties’ contract.  Although Weulander is entitled to plead alternative theories of 
recovery, the duty supplying the basis of the E-Commerce Policy breach of contract claim 
is identical to the duty supplying the basis for the negligence claim.  In both claims, 
Weulander essentially maintains that NSCU owed a duty to safeguard her funds.  See U.S. 

Bank Nat’l Ass’n, 252 F. Supp. 3d at 718–20 (finding negligence claim failed because the 





    4 See also Constr. Sys., Inc. v. Gen. Cas. Co. of Wis., No. 09-3697, 
2011 WL 3625066
, at *9 
(D. Minn. Aug. 17, 2011) (“[A] tort is independent from a breach of contract (and a separate cause 
of action can thus be brought) if a relationship would exist which would give rise to the legal duty 
without enforcement of the contract promise itself.”) (internal quotation marks and citation 
omitted); Berger v. Nationstar Mortg. LLC, 
118 F. Supp. 3d 1121, 1125
 (D. Minn. 2015) (“[U]nder 
Minnesota law, a plaintiff does not have a cause of action for negligent breach of a contractual 
duty.”).                                                                  
duty to safeguard plaintiff’s cash was “precisely the basis” for a breach of contract claim).  
Accordingly, the negligence claim is precluded by the independent duty rule.5 

    D.   Conversion                                                      
    Weulander alleges NSCU is liable for conversion because it failed to return the full 
balance of the funds despite Weulander’s demands.  Conversion is “an act of willful 
interference with personal property, done without lawful justification by which any 

person entitled thereto is deprived of use and possession.”  Cobb v. Paylease LLC, 
34 F. Supp. 3d 976, 988
 (D. Minn. 2014) (quoting DLH, Inc. v. Russ, 
566 N.W.2d 60, 71
 (Minn. 
1997)).  Because conversion is a tort, the independent duty rule also applies.  See, e.g., 
Klucas v. M.H. Graff & Assocs., No. 20-762, 
2020 WL 6275971
, at *3 (D. Minn. Oct. 26, 

2020); Staffing Specifix, Inc. v. TempWorks Mgmt. Servs., Inc., 
896 N.W.2d 115
, 125–26 
(Minn. Ct. App. 2017), aff’d, 
913 N.W.2d 687
 (Minn. 2018).                
    Like the negligence claim above, Weulander has not identified an independent 

duty that NSCU owed regarding her conversion claim that is not already apparent in the 
parties’  contract.    In  alleging  conversion,  Weulander  asserts  that  NSCU  deprived 
Weulander of her possessory interest in her funds by failing to fully recredit her accounts.  
Similarly, in alleging breach of contract, she maintains that NSCU failed to credit her 

accounts in accordance with the contract.  (Am. Compl. ¶¶ 132–43.)  These duties are the 


    5 Because it finds that the independent duty rule precludes the negligence claim, the 
Court need not address NSCU’s other arguments regarding the applicable standard of care that 
NSCU owed to Weulander or whether the economic loss doctrine bars the negligence claim. 
same, so the independent duty rule also precludes the conversion claim.6  Cf. Polaris 
Indus., Inc. v. Mangum, No. 23-614, 
2023 WL 5806741
, at *6–7 (D. Minn. Sept. 7, 2023) 

(finding conversion claim was not precluded by independent duty rule because plaintiff 
pled a common law duty of confidentiality independent from the parties’ contractual 
duties).                                                                  

    E.   Aiding and Abetting Tortious Conduct                            
    Weulander alleges NSCU is liable for aiding and abetting the third party who 
initiated the unauthorized EFTs in the commission of fraud.  The elements for an aiding 
and abetting claim are: (1) that the primary tortfeasor committed a tort that caused the 
plaintiff an injury; (2) that the defendant knows that the primary tortfeasor’s conduct 

constitutes  a  breach  of  duty;  and  (3)  that  the  defendant  substantially  assisted  or 
encouraged the primary tortfeasor in achieving the breach.  Zayed v. Associated Bank, 
N.A., 
779 F.3d 727, 733
 (8th Cir. 2015) (applying Minnesota law).  The parties do not 

dispute the first element.  The question thus is whether Weulander has plausibly alleged 
that  NSCU  knew  of  the  third-party’s  tortious  conduct,  and  that  NSCU  substantially 
assisted or encouraged the third party.  These two elements are evaluated “in tandem.”  
Witzman  v.  Lehrman,  Lehrman  &  Flom,  
601 N.W.2d 179, 188
  (Minn.  1999);  In  re 

Temporomandibular Joint Implants Prods. Liab. Litig., 
113 F.3d 1484, 1495
 (8th Cir. 1997).  


    6 Because the Court concludes that the conversion claim is precluded by the independent 
duty rule, it need not address NSCU’s other arguments, including whether Weulander can 
properly bring a conversion claim against a credit union.                 
Where there is a minimal showing of knowledge, there must be a greater showing of 
substantial assistance, and vice versa.  Witzman, 
601 N.W.2d at 188
.  Because Weulander 

plausibly alleges both knowledge and substantial assistance, the Court will deny NSCU’s 
motion to dismiss.                                                        
         1.   Knowledge                                                  
    For  the  knowledge  element,  there  must  have  been  actual  knowledge  of  the 

underlying wrongs committed.  Zayed, 
779 F.3d at 733
.  The defendant “must know that 
the conduct they are aiding and abetting is a tort.”  
Id.
 (emphasis in original).   
    Weulander has plausibly pled that NSCU had actual knowledge that the third party 
was committing fraud.  The fact that a third party linked to an IP address in Indonesia 

made multiple, incorrect password attempts to gain access to Weulander’s accounts, and 
then changed the password once gaining access, raises suspicions of fraudulent activity.  
In addition, the fact that the third party repeatedly logged into the online bank accounts 

53 times over the course of four days is also suspicious.  And then, day after day over the 
course of five weeks, NSCU processed 68 separate transactions initiated by the third party 
in Indonesia and transferred over $187,000 out of Weulander’s accounts, effectively 
depleting them.  Not only do these facts taken together suggest that NSCU knew about 

the multiple password attempts, repeated logins, and 68 separate transactions, but they 
also suggest that NSCU knew that the conduct was wrongful given how highly suspicious 
it  was.    See  Zayed,  
779 F.3d at 734
  (finding  that  complaint  as  a  whole  “alleges 
circumstances strongly indicating knowledge” sufficient to survive motion to dismiss) 
(quotation omitted).  Plus, Weulander is unable, absent discovery, to allege more specific 
facts concerning NSCU’s knowledge.  On these facts, the Court finds that Weulander has 

plausibly pled that NSCU had actual knowledge of the fraud.               
         2.   Substantial Assistance                                     
    For the substantial assistance element, Minnesota law requires an “affirmative 
step” by the aider-and-abettor that substantially advances the tortious conduct.  Am. 

Bank. of St. Paul v. TD Bank, N.A., 
713 F.3d 455, 462
 (8th Cir. 2013).  Incidental assistance 
does not satisfy this element.  Camp v. Dema, 
948 F.2d 455, 460
 (8th Cir. 1991).  Instead, 
the “[a]ssistance must further the fraud itself, and not merely constitute general aid to 
the  tortfeasor.”    Zayed,  
779 F.3d at 735
  (quotation  omitted).    In  the  context  of 

professional defendants, Minnesota law requires a showing of “something more than the 
provision of routine professional services.”  Zayed v. Associated Bank, N.A., 
913 F.3d 709, 720
 (8th Cir. 2019) (quotation omitted).                                  

    Weulander alleges NSCU substantially assisted the third party in committing fraud 
by processing and transmitting the unauthorized EFTs.  NSCU counters that the amended 
complaint fails to plead facts to support a plausible inference that NSCU substantially 
assisted or encouraged the third party.                                   

    Zayed is instructive.  Plaintiffs brought an aiding-and-abetting claim against a bank 
that provided services to scammers engaged in a Ponzi scheme that swindled millions of 
dollars from investors.  Zayed, 
779 F.3d at 730, 732
.  The bank opened an account for a 
non-registered entity to hold the investors’ money, and then authorized a non-signatory 
to withdraw millions of dollars from the investors’ money to deposit into the non-
signatory’s personal accounts.  
Id. at 735
.  The Eighth Circuit determined that such 

transactions were not “routine transfers” nor “quintessential banking activities.”  
Id.
  
Accordingly,  the  court  concluded  that  a  jury  could  reasonably  infer  that  the  bank 
misappropriated the funds in such a way that substantially assisted the scammers.  
Id.
   
    Similarly,  Weulander  pleads  sufficient  facts  to  support  her  claim  that  NSCU 

substantially  assisted  the  third  party  in  Indonesia.    There  is  no  doubt  that  NSCU’s 
processing of the 68 unauthorized EFTs assisted the third party in the commission of 
fraudulent conduct, as the third party could not have transferred Weulander’s funds out 

of her accounts if not for NSCU’s processing of the EFTs.  Thus, the issue becomes whether 
processing the 68 unauthorized EFTs constitutes NSCU’s routine professional services.  
See Zayed, 
913 F.3d at 720
.  In other words, the question is whether it was routine for 
NSCU to process and transmit, without asking questions over the course of five weeks, 68 

separate transactions initiated by someone in Indonesia, and which effectively depleted 
an accountholder’s accounts.  Like in Zayed, a jury could reasonably infer that the 68 
unauthorized EFTs were not “routine transfers” such that NSCU knowingly facilitated the 
fraudulent EFTs from Weulander’s accounts.                                

    Therefore, the Court finds that the amended complaint plausibly pleads all three 
elements of an aiding-and-abetting claim.                                 
                                CONCLUSION 
     Because the negligence and conversion claims are precluded by the independent 
duty rule, the Court will dismiss those claims.  At the same time, the Court concludes that 
Weulander has plausibly pled a claim for treble damages, breach of E-Commerce Policy, 
and aiding and abetting tortious conduct. 

ORDER

     Based on the foregoing, and  all the files,  records, and  proceedings herein,  IT IS 
HEREBY ORDERED THAT: 
     1.     Defendant’s Motion to Dismiss [Docket No. 9] is DENIED as moot; and 
     2.     Defendant’s Renewed  Motion to Dismiss  [Docket No.  17]  is GRANTED IN 
     PART and DENIED IN PART as follows: 

           a.     The  motion  is  GRANTED  as  to  Counts  VIII  (negligence)  and  IX 
                 (conversion).    Accordingly,  those  claims  are  DISMISSED  with 
                 prejudice. 
           b.     The motion is DENIED as to Counts IV (treble damages), VII (breach 
                 of contract — E-Commerce Policy), and X (aiding and abetting tortious 
                 conduct). 

DATED:  February 7, 2024                           oben Ww. (eden 
at Minneapolis, Minnesota.                         JOHN R. TUNHEIM 
                                            United States District Judge 

                                    -16- 

Trial Court Opinion

                   UNITED STATES DISTRICT COURT                          
                      DISTRICT OF MINNESOTA                              
KATHY WEULANDER,                                                         
                                      Civil No. 23-885 (JRT/LIB)         
                       Plaintiff,                                        

v.                                                                       
                                   ORDER GRANTING IN PART AND            
NORTH STAR CREDIT UNION,           DENYING IN PART DEFENDANT’S           
                                        MOTION TO DISMISS                
                      Defendant.                                         

    Aaron  David  Sampsel,  Kristen  Williams,  Carl  E.  Christensen,  and  Ryan 
    Supple, CHRISTENSEN LAW OFFICE PLLC, 305 Fifth Avenue North, Suite 375, 
    Minneapolis, MN 55401, for Plaintiff.                                

    Andrew R. Shedlock, KUTAK ROCK LLP, 60 South Sixth Street, Suite 3400, 
    Minneapolis, MN 55402, for Defendant.                                


    This action arises out of Plaintiff Kathy Weulander’s allegations that Defendant 
North  Star  Credit  Union  (“NSCU”)  improperly  processed  68  unauthorized  electronic 
transactions by a third-party, which transferred $187,380 out of Weulander’s accounts 
over the span of approximately five weeks.  Weulander brings ten causes of action against 
NSCU, including violations of the Electronic Fund Transfers Act, three breach of contract 
claims, negligence, conversion, and aiding and abetting tortious conduct.  NSCU moves to 
dismiss five of the ten counts.  Because the independent duty rule bars Weulander’s 
negligence and conversion claims, the Court will grant NSCU’s motion to dismiss as to 
those claims.  And because Weulander has plausibly alleged her treble damages, breach 
of E-Commerce Policy, and aiding-and-abetting claims, the Court will allow those claims 
to proceed.                                                               

                          BACKGROUND                                     
I.   FACTS                                                                
    A.   Weulander’s Accountholder Agreement with NSCU                   
    Kathy Weulander is a long-time savings and checking account holder with NSCU.  
(Am. Compl. ¶¶ 15–16, June 8, 2016, Docket No. 16.)  When she opened her accounts, 

Weulander agreed to NSCU’s Membership and Account Agreement, which describes the 
terms and conditions of NSCU’s services.  (Id. ¶ 21.)  The agreement also incorporates 
NSCU’s Electronic Fund Transfers Agreement and Disclosure (“EFT Agreement”) and 
“Credit Union policies.”  (Id. ¶¶ 23, 134; see also Decl. of Jennifer Stedt (“Stedt Decl.”), ¶ 

4, Ex. C (“Membership and Account Agreement”) at 2, May 19, 2023, Docket No. 15.)1  
The  EFT  Agreement  outlines  Weulander’s  rights  and  responsibilities  concerning  the 
electronic fund transfer services offered by NSCU; it explains liability and establishes the 

proper protocol for handling unauthorized transactions.  (Am. Compl. ¶¶ 24–25; see also 
Stedt Decl. ¶ 3, Ex. B at 5.)                                             



    1 At the motion to dismiss stage, the Court may consider the allegations in the complaint 
as well as “those materials that are necessarily embraced by the pleadings.”  Schriener v. Quicken 
Loans, Inc., 
774 F.3d 442, 444
 (8th Cir. 2014).  The Court may consider exhibits attached to the 
pleadings  and  contract  documents,  so  long  as  those  documents  do  not  conflict  with  the 
complaint.  Porous Media Corp. v. Pall Corp., 
186 F.3d 1077, 1079
 (8th Cir. 1999); Stahl v. U.S. 
Dept. of Agric., 
327 F.3d 697, 700
 (8th Cir. 2003).                       
    Additionally, a  copy of NSCU’s E-Commerce Policy was enclosed  when NSCU 
provided Weulander with the Membership and Account Agreement.  (Am. Compl. ¶ 153.)  

The E-Commerce Policy requires NSCU “to always safeguard member data” and explains 
the different levels of protection NSCU provides to e-commerce activities.  (Decl. of 
Jennifer Stedt, ¶ 2, Ex. A at 3–6, June 13, 2023, Docket No. 20.)         

    B.   Unauthorized Electronic Transfers of Funds                      
    On  December  13,  2022,  Weulander  learned  of  unauthorized  activity  in  her 
accounts when a legitimate check she wrote was rejected due to insufficient funds.  (Am. 
Compl. ¶ 45.)  Weulander’s attorney-in-fact, Steve Jacobson, immediately contacted 
NSCU about the rejected check.  (Id. ¶¶ 4, 46.)  Weulander and Jacobson then discovered 

that  between  November  8  and  December  13,  2022,  a  total  of  $187,380  had  been 
transferred via electronic funds transfer (“EFT”) from Weulander’s accounts to another 
bank.  (Id. ¶¶ 36, 38.)  The funds were transferred through a series of 68 individual 

transactions—usually in increments of $3,000 and often with multiple transfers executed 
on the same day.  (Id. ¶ 36.)  The EFTs effectively depleted Weulander’s accounts.  (Id. ¶ 
37.)  Jacobson immediately notified NSCU that these transactions were not authorized by 
Weulander or himself.  (Id. ¶ 46.)                                        

    An unknown third party linked to an IP address in Indonesia was responsible for 
the unauthorized EFTs.  (Id. ¶ 33.)  The third party made multiple, incorrect password 
attempts  through  NSCU’s  online  banking  portal  before  finally  gaining  access  to 
Weulander’s accounts and resetting the password on November 3, 2022.  (Id. ¶ 31.)  After 
resetting the password, the third party logged into Weulander’s accounts 53 times over 
the course of four days.  (Id. ¶ 34.)  Then, the third party executed the 68 unauthorized 

EFTs from Weulander’s savings and checking accounts over the course of approximately 
five weeks.  (Id. ¶ 36.)                                                  
    Weulander  provided  written  notice  to  NSCU  of  the  unauthorized  EFTs  and 
demanded  a  full  accounting  and  explanation  of  NSCU’s  handling  of  the  EFTs,  in 

accordance with the parties’ agreement terms.  (Id. ¶¶ 49–50.)  Six days later, NSCU 
issued payments totaling $45,000 to Weulander’s savings account.  (Id. ¶ 51.)  Weulander 
promptly wrote again to NSCU to demand a full accounting and explanation of NSCU’s 

handling of the EFTs.  (Id. ¶ 52.)  NSCU never provided the results of any investigation that 
it may have conducted, nor did it respond to Weulander’s written notices concerning the 
unauthorized EFTs.  (Id. ¶¶ 91, 94.)                                      
    Weulander  subsequently  brought  this  action,  alleging  that  NSCU  improperly 

processed the 68 unauthorized EFTs and failed to follow investigation procedures after 
the fraudulent activity was reported, all in violation of federal law and the parties’ 
contract.  (Id. ¶¶ 2, 5–6.)  Weulander brings ten claims against NSCU, including for 
violations of the Electronic Fund Transfers Act (“EFTA”), breach of contract, negligence, 

conversion, and aiding and abetting tortious conduct.  (See id.)          
II.  PROCEDURAL HISTORY                                                   
    After NSCU filed a motion to dismiss Weulander’s original complaint for failure to 
state a claim, Weulander filed an amended complaint.  (See generally Def.’s Mot. Dismiss, 
May 18, 2023, Docket No. 9; Am. Compl.)  NSCU now moves to dismiss five of the ten 
counts in the amended complaint: (1) a claim for treble damages under the Electronic 

Fund Transfers Act; (2) breach of contract through violation of the E-Commerce Policy; (3) 
negligence; (4) conversion; and (5) aiding and abetting tortious conduct.  (Def.’s Renewed 
Mot. Dismiss, June 13, 2023, Docket No. 17.)                              

                           DISCUSSION                                    
I.   STANDARD OF REVIEW                                                   
    In reviewing a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), the 
Court considers all facts alleged in the complaint as true to determine if the complaint 
states a “claim to relief that is plausible on its face.”  Braden v. Wal-Mart Stores, Inc., 
588 F.3d 585, 594
 (8th Cir. 2009) (quoting Ashcroft v. Iqbal, 
556 U.S. 662, 678
 (2009)).  “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.”  
Iqbal, 
556 U.S. at 678
.  The Court construes the complaint in the light most favorable to 

the plaintiff, drawing all inferences in the plaintiff’s favor.  Ashley Cnty. v. Pfizer, Inc., 
552 F.3d 659, 665
 (8th Cir. 2009).  But the Court is “not bound to accept as true a legal 
conclusion couched as a factual allegation.”  Papasan v. Allain, 
478 U.S. 265, 286
 (1986).  
A complaint need not have “detailed factual allegations” but must include more than 

conclusory statements or “a formulaic recitation of the elements” to meet the plausibility 
standard.  Bell Atl. Corp. v. Twombly, 
550 U.S. 544, 555
 (2007).          
II.  DEFENDANT’S MOTION TO DIMISS                                         
    Because Weulander’s negligence and conversion claims are precluded by the 

independent duty rule, the Court will grant NSCU’s motion with respect to those claims.  
The Court will deny the motion as to the remaining challenged claims.2    
    A.       Treble Damages Under the Electronic Fund Transfers Act      
    Weulander alleges NSCU violated various provisions of the EFTA, which establishes 

the  rights,  liabilities,  and  responsibilities  of  participants  in  electronic  fund  transfer 
activities.  See 
15 U.S.C. § 1693
, et seq.  In addition, Weulander alleges she is entitled to 
treble damages pursuant to section 1693f(e) of the EFTA.  NSCU does not challenge 
Weulander’s claims that it violated the EFTA; instead, it contends that Weulander has 

failed to state a claim for treble damages.                               
    Section 1693f allows a plaintiff to seek treble damages if a financial institution (1) 
fails to comply with certain investigation requirements before declining to provisionally 

credit  the  plaintiff  with  the  disputed  funds,  or  (2)  otherwise  acts  unreasonably  in 
determining whether the account charges were in error.  15 U.S.C. § 1693f(e).  Weulander 
alleges she is entitled to treble damages because NSCU did not make a good faith 




    2 As a threshold matter, the Court will deny NSCU’s first motion to dismiss as moot 
because Weulander filed an amended complaint in response.  See Cartier v. Wells Fargo Bank, 
N.A., 
547 F. App’x 800, 803
 (8th Cir. 2013) (“Some courts, as a matter of course, treat an amended 
complaint as mooting a pending motion to dismiss the original complaint.”).   
investigation or have a reasonable basis for believing that the EFTs were authorized based 
on evidence available at the time of any investigation performed.         

    The Court finds that Weulander has asserted allegations that support a plausible 
claim for treble damages.  The plausibility standard does not require highly detailed 
factual allegations, as NSCU appears to maintain.  See Twombly, 
550 U.S. at 555
.  Instead, 
a plaintiff must support her allegations with sufficient facts that allow the court to 

reasonably infer that the defendant is liable.  Iqbal, 
556 U.S. at 678
.  Here, Weulander 
alleges that NSCU did not provide her with information regarding any investigation (or 
even confirm that it conducted one) despite her requests; that NSCU did not recredit 

Weulander’s accounts for the full $187,380; and that 68 EFTs initiated by an Indonesian 
IP address, which nearly drained Weulander’s accounts, should have put NSCU on notice 
that the EFTs were likely fraudulent.  Weulander has pled sufficient facts to proceed with 
her treble damages claim.                                                 

    NSCU argues that Weulander fails to support her allegations that NSCU “knowingly 
and willfully” concluded that the EFTs were not in error or that NSCU failed to make a 
good faith investigation of the EFTs.3  But one of Weulander’s central allegations is that 



    3 NSCU also points to two cases where courts have dismissed claims for treble damages 
because the plaintiff failed to meet the plausibility standard.  But NSCU’s argument is unavailing, 
and the cases it cites are inapposite to this case.  See Mountcastle v. SunTrust Bank, No. 12-885, 
2013 WL 588981
, at *1, 4 (D. Md. Feb. 12, 2013) (plaintiff had knowledge of the financial 
institution’s investigation of the unauthorized activity, and he was primarily challenging the 
institution’s rejection of his claim for relief); Houston v. Fifth Third Bank, No. 18-5981, 2019 WL 
NSCU failed to provide her with any information about any investigation performed 
regarding the unauthorized EFTs.  Weulander could not provide more detailed factual 

allegations about NSCU’s investigation when she was never provided any documentation 
concerning that investigation to begin with.  The Court will not penalize Weulander for 
NSCU’s failures.  Weulander therefore has plausibly alleged a claim for treble damages 
under the EFTA.                                                           

    B.        Breach of Contract – E-Commerce Policy                     
    Weulander brings three breach of contract claims against NSCU.  Relevant to the 
instant  motion,  Weulander  alleges  NSCU  failed  to  implement,  utilize,  and  monitor 
appropriate  fraud  detection  safeguards  in  violation  of  its  E-Commerce  Policy.    In 

Minnesota, the elements for breach of contract are “(1) formation of a contract, (2) 
performance by plaintiff of any conditions precedent to his right to demand performance 
by the defendant, and (3) breach of the contract by defendant.”  Lyon Fin. Servs., Inc. v. 

Illinois Paper & Copier Co., 
848 N.W.2d 539, 543
 (Minn. 2014) (quotation omitted).  The 
only element NSCU challenges is the first one—that no contract was formed.  In support, 
NSCU argues that the E-Commerce Policy is not a contract that NSCU could breach 
because it is just a policy.  The Court disagrees.                        





1200574, at *1 (N.D. Ill. Mar. 14, 2019) (financial institution provided written documentation to 
the plaintiff concerning its investigation of the alleged unauthorized activity). 
    The  E-Commerce  Policy  is  incorporated  as  part  of  the  terms  of  the  parties’ 
contract.  The Membership and Account Agreement explicitly states that the parties 

agreed  to  the  terms  and  conditions  of  NSCU’s  “Credit  Union  policies,”  and  the  E-
Commerce Policy is one of the credit union’s policies.  (See Am. Compl. ¶ 23; Membership 
and Account Agreement at 2.)  Even though the E-Commerce Policy is not itself a separate 
contract, the Membership and Account Agreement encompasses the E-Commerce Policy 

as part of its terms and conditions.  Consequently, Weulander has plausibly alleged that 
NSCU breached the terms of the parties’ contract by failing to adhere to the E-Commerce 
Policy.                                                                   

    C.   Negligence                                                      
    The elements for negligence are (1) duty, (2) breach of the duty, (3) causation, and 
(4) damages.  Schweich v. Ziegler, Inc., 
463 N.W.2d 722, 729
 (Minn. 1990).  Weulander 
alleges that NSCU, as a professional credit union, owed a duty of care to safeguard her 

funds from unauthorized access by third parties and from unauthorized EFTs.  She 
maintains NSCU breached that duty in two ways: (1) by failing to exercise ordinary and 
reasonable care to safeguard Weulander’s accounts from unauthorized access by third 
parties; and (2) by failing to follow its own error resolution policies to implement security 

measures that would prevent unauthorized access or unauthorized EFTs.  NSCU counters 
that the negligence claim is precluded by the independent duty rule.      
    The independent duty rule provides that “when a contract defines a relationship 
between  two  parties,  a  plaintiff  is  not  entitled  to  recover  tort  damages  save  for 
exceptional cases in which a breach of contract ‘constitutes or is accompanied by an 
independent tort.’”  Blue Cross and Blue Shield of N.C. v. Rite Aid Corp., 
519 F. Supp. 3d 522
, 545 (D. Minn. 2021) (quoting Russo v. NCS Pearson, Inc., 
462 F. Supp. 2d 981, 994
 (D. 
Minn. 2006); Wild v. Rarig, 
234 N.W.2d 775, 789
 (Minn. 1975)).  Under the independent 
duty rule, the duty supporting a negligence claim must arise from something other than 
a contract between the parties; it must exist “without enforcement of the contract 

promise itself.”  U.S. Bank Nat’l Ass’n v. San Antonio Cash Network, 
252 F. Supp. 3d 714, 718
 (D. Minn. 2017) (quotation omitted).4                                 
    The Court finds that Weulander has not alleged an independent duty beyond that 

in the parties’ contract.  Although Weulander is entitled to plead alternative theories of 
recovery, the duty supplying the basis of the E-Commerce Policy breach of contract claim 
is identical to the duty supplying the basis for the negligence claim.  In both claims, 
Weulander essentially maintains that NSCU owed a duty to safeguard her funds.  See U.S. 

Bank Nat’l Ass’n, 252 F. Supp. 3d at 718–20 (finding negligence claim failed because the 





    4 See also Constr. Sys., Inc. v. Gen. Cas. Co. of Wis., No. 09-3697, 
2011 WL 3625066
, at *9 
(D. Minn. Aug. 17, 2011) (“[A] tort is independent from a breach of contract (and a separate cause 
of action can thus be brought) if a relationship would exist which would give rise to the legal duty 
without enforcement of the contract promise itself.”) (internal quotation marks and citation 
omitted); Berger v. Nationstar Mortg. LLC, 
118 F. Supp. 3d 1121, 1125
 (D. Minn. 2015) (“[U]nder 
Minnesota law, a plaintiff does not have a cause of action for negligent breach of a contractual 
duty.”).                                                                  
duty to safeguard plaintiff’s cash was “precisely the basis” for a breach of contract claim).  
Accordingly, the negligence claim is precluded by the independent duty rule.5 

    D.   Conversion                                                      
    Weulander alleges NSCU is liable for conversion because it failed to return the full 
balance of the funds despite Weulander’s demands.  Conversion is “an act of willful 
interference with personal property, done without lawful justification by which any 

person entitled thereto is deprived of use and possession.”  Cobb v. Paylease LLC, 
34 F. Supp. 3d 976, 988
 (D. Minn. 2014) (quoting DLH, Inc. v. Russ, 
566 N.W.2d 60, 71
 (Minn. 
1997)).  Because conversion is a tort, the independent duty rule also applies.  See, e.g., 
Klucas v. M.H. Graff & Assocs., No. 20-762, 
2020 WL 6275971
, at *3 (D. Minn. Oct. 26, 

2020); Staffing Specifix, Inc. v. TempWorks Mgmt. Servs., Inc., 
896 N.W.2d 115
, 125–26 
(Minn. Ct. App. 2017), aff’d, 
913 N.W.2d 687
 (Minn. 2018).                
    Like the negligence claim above, Weulander has not identified an independent 

duty that NSCU owed regarding her conversion claim that is not already apparent in the 
parties’  contract.    In  alleging  conversion,  Weulander  asserts  that  NSCU  deprived 
Weulander of her possessory interest in her funds by failing to fully recredit her accounts.  
Similarly, in alleging breach of contract, she maintains that NSCU failed to credit her 

accounts in accordance with the contract.  (Am. Compl. ¶¶ 132–43.)  These duties are the 


    5 Because it finds that the independent duty rule precludes the negligence claim, the 
Court need not address NSCU’s other arguments regarding the applicable standard of care that 
NSCU owed to Weulander or whether the economic loss doctrine bars the negligence claim. 
same, so the independent duty rule also precludes the conversion claim.6  Cf. Polaris 
Indus., Inc. v. Mangum, No. 23-614, 
2023 WL 5806741
, at *6–7 (D. Minn. Sept. 7, 2023) 

(finding conversion claim was not precluded by independent duty rule because plaintiff 
pled a common law duty of confidentiality independent from the parties’ contractual 
duties).                                                                  

    E.   Aiding and Abetting Tortious Conduct                            
    Weulander alleges NSCU is liable for aiding and abetting the third party who 
initiated the unauthorized EFTs in the commission of fraud.  The elements for an aiding 
and abetting claim are: (1) that the primary tortfeasor committed a tort that caused the 
plaintiff an injury; (2) that the defendant knows that the primary tortfeasor’s conduct 

constitutes  a  breach  of  duty;  and  (3)  that  the  defendant  substantially  assisted  or 
encouraged the primary tortfeasor in achieving the breach.  Zayed v. Associated Bank, 
N.A., 
779 F.3d 727, 733
 (8th Cir. 2015) (applying Minnesota law).  The parties do not 

dispute the first element.  The question thus is whether Weulander has plausibly alleged 
that  NSCU  knew  of  the  third-party’s  tortious  conduct,  and  that  NSCU  substantially 
assisted or encouraged the third party.  These two elements are evaluated “in tandem.”  
Witzman  v.  Lehrman,  Lehrman  &  Flom,  
601 N.W.2d 179, 188
  (Minn.  1999);  In  re 

Temporomandibular Joint Implants Prods. Liab. Litig., 
113 F.3d 1484, 1495
 (8th Cir. 1997).  


    6 Because the Court concludes that the conversion claim is precluded by the independent 
duty rule, it need not address NSCU’s other arguments, including whether Weulander can 
properly bring a conversion claim against a credit union.                 
Where there is a minimal showing of knowledge, there must be a greater showing of 
substantial assistance, and vice versa.  Witzman, 
601 N.W.2d at 188
.  Because Weulander 

plausibly alleges both knowledge and substantial assistance, the Court will deny NSCU’s 
motion to dismiss.                                                        
         1.   Knowledge                                                  
    For  the  knowledge  element,  there  must  have  been  actual  knowledge  of  the 

underlying wrongs committed.  Zayed, 
779 F.3d at 733
.  The defendant “must know that 
the conduct they are aiding and abetting is a tort.”  
Id.
 (emphasis in original).   
    Weulander has plausibly pled that NSCU had actual knowledge that the third party 
was committing fraud.  The fact that a third party linked to an IP address in Indonesia 

made multiple, incorrect password attempts to gain access to Weulander’s accounts, and 
then changed the password once gaining access, raises suspicions of fraudulent activity.  
In addition, the fact that the third party repeatedly logged into the online bank accounts 

53 times over the course of four days is also suspicious.  And then, day after day over the 
course of five weeks, NSCU processed 68 separate transactions initiated by the third party 
in Indonesia and transferred over $187,000 out of Weulander’s accounts, effectively 
depleting them.  Not only do these facts taken together suggest that NSCU knew about 

the multiple password attempts, repeated logins, and 68 separate transactions, but they 
also suggest that NSCU knew that the conduct was wrongful given how highly suspicious 
it  was.    See  Zayed,  
779 F.3d at 734
  (finding  that  complaint  as  a  whole  “alleges 
circumstances strongly indicating knowledge” sufficient to survive motion to dismiss) 
(quotation omitted).  Plus, Weulander is unable, absent discovery, to allege more specific 
facts concerning NSCU’s knowledge.  On these facts, the Court finds that Weulander has 

plausibly pled that NSCU had actual knowledge of the fraud.               
         2.   Substantial Assistance                                     
    For the substantial assistance element, Minnesota law requires an “affirmative 
step” by the aider-and-abettor that substantially advances the tortious conduct.  Am. 

Bank. of St. Paul v. TD Bank, N.A., 
713 F.3d 455, 462
 (8th Cir. 2013).  Incidental assistance 
does not satisfy this element.  Camp v. Dema, 
948 F.2d 455, 460
 (8th Cir. 1991).  Instead, 
the “[a]ssistance must further the fraud itself, and not merely constitute general aid to 
the  tortfeasor.”    Zayed,  
779 F.3d at 735
  (quotation  omitted).    In  the  context  of 

professional defendants, Minnesota law requires a showing of “something more than the 
provision of routine professional services.”  Zayed v. Associated Bank, N.A., 
913 F.3d 709, 720
 (8th Cir. 2019) (quotation omitted).                                  

    Weulander alleges NSCU substantially assisted the third party in committing fraud 
by processing and transmitting the unauthorized EFTs.  NSCU counters that the amended 
complaint fails to plead facts to support a plausible inference that NSCU substantially 
assisted or encouraged the third party.                                   

    Zayed is instructive.  Plaintiffs brought an aiding-and-abetting claim against a bank 
that provided services to scammers engaged in a Ponzi scheme that swindled millions of 
dollars from investors.  Zayed, 
779 F.3d at 730, 732
.  The bank opened an account for a 
non-registered entity to hold the investors’ money, and then authorized a non-signatory 
to withdraw millions of dollars from the investors’ money to deposit into the non-
signatory’s personal accounts.  
Id. at 735
.  The Eighth Circuit determined that such 

transactions were not “routine transfers” nor “quintessential banking activities.”  
Id.
  
Accordingly,  the  court  concluded  that  a  jury  could  reasonably  infer  that  the  bank 
misappropriated the funds in such a way that substantially assisted the scammers.  
Id.
   
    Similarly,  Weulander  pleads  sufficient  facts  to  support  her  claim  that  NSCU 

substantially  assisted  the  third  party  in  Indonesia.    There  is  no  doubt  that  NSCU’s 
processing of the 68 unauthorized EFTs assisted the third party in the commission of 
fraudulent conduct, as the third party could not have transferred Weulander’s funds out 

of her accounts if not for NSCU’s processing of the EFTs.  Thus, the issue becomes whether 
processing the 68 unauthorized EFTs constitutes NSCU’s routine professional services.  
See Zayed, 
913 F.3d at 720
.  In other words, the question is whether it was routine for 
NSCU to process and transmit, without asking questions over the course of five weeks, 68 

separate transactions initiated by someone in Indonesia, and which effectively depleted 
an accountholder’s accounts.  Like in Zayed, a jury could reasonably infer that the 68 
unauthorized EFTs were not “routine transfers” such that NSCU knowingly facilitated the 
fraudulent EFTs from Weulander’s accounts.                                

    Therefore, the Court finds that the amended complaint plausibly pleads all three 
elements of an aiding-and-abetting claim.                                 
                                CONCLUSION 
     Because the negligence and conversion claims are precluded by the independent 
duty rule, the Court will dismiss those claims.  At the same time, the Court concludes that 
Weulander has plausibly pled a claim for treble damages, breach of E-Commerce Policy, 
and aiding and abetting tortious conduct. 

ORDER

     Based on the foregoing, and  all the files,  records, and  proceedings herein,  IT IS 
HEREBY ORDERED THAT: 
     1.     Defendant’s Motion to Dismiss [Docket No. 9] is DENIED as moot; and 
     2.     Defendant’s Renewed  Motion to Dismiss  [Docket No.  17]  is GRANTED IN 
     PART and DENIED IN PART as follows: 

           a.     The  motion  is  GRANTED  as  to  Counts  VIII  (negligence)  and  IX 
                 (conversion).    Accordingly,  those  claims  are  DISMISSED  with 
                 prejudice. 
           b.     The motion is DENIED as to Counts IV (treble damages), VII (breach 
                 of contract — E-Commerce Policy), and X (aiding and abetting tortious 
                 conduct). 

DATED:  February 7, 2024                           oben Ww. (eden 
at Minneapolis, Minnesota.                         JOHN R. TUNHEIM 
                                            United States District Judge 

                                    -16- 

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