McFarland v. Citibank (South Dakota), N.A.
Alvin S. McFarland appealed the trial court's decision to grant Citibank (South Dakota), N.A.'s motion for summary judgment in a credit card debt collection suit and deny McFarland's cross-motion. Citibank sued McFarland for unpaid credit card debt based on an "account stated" cause of action, among other claims. McFarland challenged the competency of Citibank's affidavit evidence and argued that "account stated" was not applicable to credit card collections. The appellate court affirmed the trial court's judgment, finding the affidavit competent and confirming that an "account stated" cause of action is appropriate for credit card debt collection in Texas.