Jamal Jackson v. Global Lending Services LLC — Court Affirms Arbitration Compulsion
Summary
On April 7, 2026, the United States District Court for the Southern District of Florida adopted Magistrate Judge Jared M. Strauss's Report and Recommendation, granting Defendant Global Lending Services, LLC's Motion to Dismiss and to Compel Arbitration and staying the case pending arbitration. The court overruled Plaintiff Jamal Jackson's objections to the Report, which had recommended dismissal based on an enforceable arbitration provision in the auto-loan Retail Installment Sales Contract. Jackson had alleged violations of the Fair Credit Reporting Act, Fair Debt Collection Practices Act, Florida Consumer Collection Practices Act, and Truth in Lending Act, claiming the lender continued collection efforts and furnished inaccurate credit information after the loan was satisfied. The arbitration clause, governed by the Federal Arbitration Act, requires neutral binding arbitration for any dispute arising from the contract or credit relationship.
Consumer lenders and auto-finance companies using retail installment sales contracts should audit their arbitration provisions to confirm the clause expressly elects binding arbitration over court action, invokes the FAA as governing law, and survives payoff or contract termination. The breadth of the clause in Jackson—covering "any dispute...whether in contract, tort, statute or otherwise" including the arbitrability question—was a feature the court upheld, not a defect.
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What changed
The court affirmed the Magistrate Judge's recommendation and ordered that the case be dismissed without prejudice and stayed pending arbitration, rejecting Jackson's objections to the Report and Recommendation. The arbitration provision in the Retail Installment Sales Contract, which provides that disputes "shall, at your or our election, be resolved by neutral, binding arbitration and not by a court action" and is governed by the Federal Arbitration Act, was found enforceable. Jackson's claims under the Fair Credit Reporting Act, Fair Debt Collection Practices Act, Florida Consumer Collection Practices Act, and Truth in Lending Act—all arising from or relating to the credit transaction—must be pursued through arbitration rather than litigation.
For financial services and consumer lending firms, this ruling reinforces the enforceability of arbitration provisions in retail installment sales contracts for auto financing. Firms should ensure their arbitration clauses clearly state that disputes may be resolved by neutral binding arbitration rather than court action, include a governing-law clause citing the Federal Arbitration Act, and contain survival provisions so the arbitration obligation persists beyond contract termination. Consumers with disputes over paid-off accounts who are subject to broad arbitration clauses will need to pursue relief through arbitration rather than court.
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April 7, 2026 Get Citation Alerts Download PDF Add Note
Jamal Jackson v. Global Lending Services, LLC
District Court, S.D. Florida
- Citations: None known
- Docket Number: 0:25-cv-62117
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 25-62117-CIV-DAMIAN
JAMAL JACKSON,
Plaintiff,
v.
GLOBAL LENDING SERVICES, LLC,
Defendant.
__________________________________/
ORDER AFFIRMING AND ADOPTING
MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION
THIS CAUSE is before the Court on Magistrate Judge Jared M. Strauss’s Report and
Recommendation (“Report”), entered on February 17, 2026 [ECF No. 33], recommending
that the Court grant in part Defendant’s Motion to Dismiss Plaintiff’s Amended Complaint
and to Compel Arbitration ECF No. 18. Plaintiff filed timely
Objections to the Report ECF No. 37, and Defendant filed a Response to
Plaintiff’s Objections [ECF No. 40]. The matter is now ripe for review.
THE COURT has reviewed the Motion to Dismiss, the Report, the Objections and
Response thereto, the pertinent portions of the record, and applicable law and is otherwise
fully advised.
For the reasons set forth below, this Court adopts the Report, grants the Motion to
Dismiss, and stays this matter pending arbitration.
I. BACKGROUND
The background facts and procedural history are laid out in detail in the Report, so
this Court does not rehash them in detail here but recaps those particularly relevant to this
Court’s consideration of the Report and Objections.
Plaintiff, Jamal Jackson (“Jackson”), proceeding pro se, filed a Complaint in County
Court in and for Broward County, Florida, against Defendant, Global Lending Services, LLC
(“GLS”), on September 12, 2025. [ECF No. 1-2]. In the Complaint, Jackson alleged
violations of the Fair Credit Reporting Act (“FCRA”), Fair Debt Collection Practices Act
(“FDCPA”), and the Florida Consumer Collection Practices Act (“FCCPA”). On October
21, 2025, GLS removed the action to this Court on the basis of subject matter and
supplemental jurisdiction. [ECF No. 1].
Jackson filed an Amended Complaint on November 12, 2025. [ECF No. 14]. In the
Amended Complaint, Jackson alleges claims under the Fair Credit Reporting Act (“FCRA”),
the FDCPA, and the Truth in Lending Act (“TILA”). [ECF No. 1-2 at 3-4.]. The Amended
Complaint includes two state-law claims. Id. On November 26, 2025, Defendant moved to
dismiss or stay the case pursuant to a binding arbitration agreement. [ECF No. 18]. As set
forth in the Amended Complaint, to finance an automobile purchase, Jackson and a co-buyer
entered a Retail Installment Sales Contract (the “Contract”) with a seller that assigned its
contractual interest to GLS. The Contract included an arbitration provision, which provides:
“Agreement to Arbitrate: By signing below, you agree that, pursuant to the Arbitration
Provision on the reverse side of this contract, you or we may elect to resolve any dispute by
neutral binding arbitration and not by a court action.” [ECF No. 18-1]. The Arbitration
Provision also included, on the flipside of the Contract, a provision which provides, in part:
Any claim or dispute, whether in contract, tort, statute or otherwise
(including the interpretation and scope of this Arbitration Provision, and the
arbitrability of the claim or dispute), between you and us or our employees,
agents, successors or assigns, which arises out of or relates to your credit
application, purchase or condition of this vehicle, this contract or any resulting
transaction or relationship (including any such relationship with third parties
who do not sign this contract) shall, at your or our election, be resolved by
neutral, binding arbitration and not by a court action.
[ECF No. 18-1 at 7]. The Arbitration Provision then clarifies that it “shall be governed by the
Federal Arbitration Act . . . .” Id. Elsewhere, the Contract’s arbitration provision addresses
termination and indicates that the arbitration provision “shall survive any termination, payoff
or transfer of this contract.” Id. Regarding waiver, the Arbitration Provision specifies,
“Neither you nor we waive the right to arbitrate by using self-help remedies . . . .” Id.
Jackson alleges that, several years after entering the Contract, he fully paid off the
remaining balance and thus satisfied the loan. [ECF No. 14]. He alleges that GLS accepted
and acknowledged the payment but “continued collection communications and harassing
calls . . . .” Id. ¶ 10. And, Jackson alleges that GLS provided false credit information to credit
reporting agencies after the loan balance was paid off. Id. ¶ 11. Jackson asserts that GLS has,
among other things, “defaulted in state court,” “engaged in settlement communications,” and
“requested extensions.” [ECF No. 19 at 4].
As indicated above, GLS moved to dismiss or stay the case pending arbitration based
on the Arbitration Provision. [ECF No. 18 at 1-2].
II. LEGAL STANDARD
When a magistrate judge’’s “disposition” is properly objected to, district courts must
review the disposition de novo. Fed. R. Civ. P. 72(b)(3). A proper objection “identifie[s]
specific findings set forth in the R & R and articulate[s] a legal ground for objection.”
Leatherwood v. Anna’s Linens Co., 384 F. App’’x 853, 857 (11th Cir. 2010) (citation omitted).
“Frivolous, conclusive, or general objections need not be considered by the district court.” Id.
(quoting Marsden v. Moore, 847 F.2d 1536, 1548 (11th Cir. 1988) (internal quotation marks
and other citation omitted)); see also Russell v. United States, No. 11-20557-Civ, 2012 WL
10026019, at *1 (S.D. Fla. Apr. 17, 2012) (declining to address general or blanket objections
not specifically identifying aspects of the Magistrate Judge’s report to which the petitioner
objected). A party’s objections are improper, however, if they expand upon and reframe
arguments already made and considered by the magistrate judge, or simply disagree with the
magistrate judge’s conclusions. See Melillo v. United States, No. 17-CV-80489, 2018 WL
4258355, at *1 (S.D. Fla. Sept. 6, 2018) (Bloom, J.); see also Marlite, Inc. v. Eckenrod, No. 10-
23641-CIV, 2012 WL 3614212, at *2 (S.D. Fla. Aug. 21, 2012) (Moreno, J.) (“It is improper
for an objecting party to ... submit [ ] papers to a district court which are nothing more than a
rehashing of the same arguments and positions taken in the original papers submitted to the
Magistrate Judge. Clearly, parties are not to be afforded a ‘second bite at the apple’ when they
file objections to a R & R.”) (quoting Camardo v. Gen. Motors Hourly-Rate Emps. Pension Plan, 806 F. Supp. 380, 382 (W.D.N.Y. 1992)). When the objecting party has not properly objected
to the magistrate judge’s findings, “the court need only satisfy itself that there is no clear error
on the face of the record in order to accept the recommendation.” Keaton v. United States, No.
14-21230-CIV, 2015 WL 12780912, at *1 (S.D. Fla. May 4, 2015) (Altonaga, J.); see also Lopez
v. Berryhill, No. 17-CV-24263, 2019 WL 2254704, at *2 (S.D. Fla. Feb. 26, 2019) (Ungaro, J.)
(stating that a district judge “evaluate[s] portions of the R & R not objected to under a clearly
erroneous standard of review” (citing Davis v. Apfel, 93 F. Supp. 2d 1313, 1317 (M.D. Fla.
2000))).
III. DISCUSSION
As an initial matter, this Court observes that Jackson’s Objections are, at bottom, a
rehashing of the same arguments, somewhat expanded upon, that he made in the underlying
Response to the Motion to Dismiss. Jackson essentially disagrees with the Magistrate Judge
and asks this Court to address the very same arguments he presented to him. This is improper
and is a sufficient basis for this Court to review the Report under the clear-error standard.
Nonetheless, this Court has engaged in a de novo review of the record (which review confirms
that Jackson is making the same arguments before this Court that he made to the Magistrate
Judge).
In his Objections, which are construed liberally in light of Jackson’s pro se status,
Jackson argues that the Magistrate Judge erred by (1) failing to acknowledge that the
Arbitration Provision does not extend to Jackson’s claims; (2) that the Arbitration Provision
did not survive the full payoff of the loan; (3) that GLS is now estopped from invoking the
Arbitration Provision; (4) that GLS has duties, including statutory duties, that arise outside
of the contract; (5) that due process and the Constitution require that Jackson be permitted to
pursue his claims; and (6) that GLS waived its rights to pursue arbitration. See generally Obj.
Based on a de novo review of the record and having carefully considered Jackson’s Objections,
this Court overrules them.
This Court has carefully considered the parties’ memoranda and Judge Strauss’s
Report, and, as stated above, Judge Strauss carefully and thoroughly addressed each of the
issues raised in Jackson’s Response to the Motion, which are the same issues raised in the
Objections to the Report. This Court has undertaken a careful review of the underlying
memoranda and the Report and agrees with Judge Strauss’s reasoning and conclusions.
As Judge Strauss concluded, this Court agrees, on the record before it, that the
Arbitration Provision does extend to Jackson’s claims despite Jackson’s payoff of the loan at
issue and that Jackson has not shown that enforcement of the Arbitration Provision would
violate his Constitutional rights. This Court also agrees that despite the record activity
identified by Jackson, GLS did not waive its rights to pursue arbitration. In short, Jackson
has not demonstrated any reason why the Magistrate Judge’s conclusions were incorrect, and,
to the contrary, the undersigned agrees with the Magistrate Judge’s analysis and finds Jackson
has shown no reason in his Objections for this Court to disagree with the Magistrate Judge’s
conclusions.
I. CONCLUSION
In sum, this Court agrees with Magistrate Judge Strauss’s well-reasoned determination
that, under the circumstances presented, the parties are bound by the Arbitration Provision in
their Contract. As such, this Court agrees that this matter shall be arbitrated.
Accordingly, for the reasons stated in Magistrate Judge Strauss’s Report, and upon de
novo review, it is hereby
ORDERED AND ADJUDGED that the Report and Recommendation [ECF No.
33] is AFFIRMED AND ADOPTED and incorporated herein for all purposes, including
appellate review. It is further
ORDERED AND ADJUDGED that the Motion to Dismiss and Compel Arbitration
[ECF No. 18] is GRANTED IN PART. This Action is STAYED pending binding
arbitration.
The Clerk is directed to CLOSE this case for administrative purposes pending
arbitration.
The Court DIRECTS the Clerk of Court to mail a copy of this Order to Plaintiff, Jamal
Jackson, 1601 NW 7th Court, Fort Lauderdale, FL 33311.
DONE AND ORDERED in Chambers in the Southern District of Florida, this 7th
day of April, 2026.
MELISSA 1.0. oy
UNITED STATES DISTRICT JUDGE
cc: Counsel of record
Jamal Jackson
1601 NW 7th Cout
Fort Lauderdale, FL 33311
954-444-4624
PRO SE
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