CS-2026-1472 - BANK OF AMERICA, N.A. v. TANGELA EKHOFF

What's This Case About?

Let’s get one thing straight: Bank of America is suing a woman in Oklahoma for $3,723.97 — not because she robbed a branch, not because she counterfeited a Visa, not even because she went on a $3,800 avocado toast spree — but because she stopped paying her credit card bill. And now, in a twist that feels less like Law & Order and more like The Office’s accounting department, one of the largest financial institutions in the world has sent a lawyer to file a lawsuit over less than four grand. Yes, you read that right: a national bank, worth more than most small countries, is in court over an amount that wouldn’t even cover the down payment on a used Honda Civic.

Tangela Ekhoff, a resident of Tulsa, Oklahoma, is the defendant in this drama. She’s not accused of fraud, identity theft, or any kind of financial wizardry — just the quiet, unceremonious act of nonpayment. At some point, she opened a Bank of America credit card, presumably to buy groceries, gas, or maybe that one Amazon impulse purchase we all regret at 2 a.m. The account, ending in 8473, had a credit limit of $3,000 — which, by the way, she blew past like a teenager with their parents’ Amex. By July 2024, her balance had ballooned to $3,848.97, thanks in part to an interest rate of 28.24% on purchases — a number so high it makes loan sharks blush. The account was officially “charged off” on July 31, 2024, which is banker-speak for “we’ve given up on getting paid, but we’re still coming after you.” The last payment she made? December 6, 2024 — over a year before the lawsuit was filed. So for at least seven months, Tangela lived in the financial twilight zone: no payments, no resolution, just silence and compounding interest.

Now, enter Bank of America, stage left, flanked by the legal cavalry: Nelson and Kennard, LLP, a debt collection law firm based in Colorado. On January 8, 2026, they filed a petition in the District Court of Tulsa County, alleging the most mundane of legal offenses — breach of contract. That’s the legal way of saying, “You agreed to pay us, and you didn’t.” No violence, no deception, just a broken promise written in fine print and sealed with a signature somewhere in the depths of a credit card application. The bank claims Tangela violated the terms of her agreement by failing to make monthly payments, and now they want the court to force her to pay up — or at least acknowledge that she owes the money. The amount they’re seeking? $3,723.97, which is slightly less than the $3,848.97 balance at charge-off, likely due to some internal accounting adjustment or a last-minute credit. Either way, it’s still chump change for a bank that reported $25 billion in profit last year. But hey, when you’re in the business of collecting debt, every dollar counts — even the ones stuck in a Tulsa mailbox.

So why are we here, in a courtroom, over this? Because this is how modern debt collection works in America. When someone falls behind on a credit card, the bank doesn’t send a concerned text. They don’t knock on your door with a casserole and a “thinking of you” card. No, they hand your file to a law firm that specializes in suing people for unpaid balances. The lawsuit itself is boilerplate — a form petition that’s probably used hundreds of times a day across the country. Paragraph 1: Bank exists. Paragraph 2: You live here. Paragraph 3: You owe money. Paragraph 4: You didn’t pay. It’s less a legal argument and more a bureaucratic inevitability, like getting a parking ticket in a poorly marked zone. The claim is breach of contract — a term that sounds dramatic but really just means “you broke the deal.” And in this case, the deal was: use our money, pay us back with interest, don’t ghost us. Tangela failed on the last part, and now the machine kicks in.

What does Bank of America actually want? $3,723.97, plus court costs — things like filing fees, sheriff’s fees, and process server charges, which could tack on a few hundred more. Is that a lot of money? For most people, yes — that’s rent, car repairs, or a solid chunk of student debt. But for a bank? It’s a rounding error. To put it in perspective, Bank of America spends more on coffee for its executives in a week than it’s suing Tangela for. And yet, here we are. Because in the debt collection game, it’s not about the amount — it’s about the precedent, the paperwork, the cold, mechanical pursuit of every dollar owed, no matter how small. They’re not trying to get rich off Tangela; they’re trying to send a message to everyone else: We see you. We will find you. And we will sue you.

Now, let’s talk about the absurdity of it all. The most ridiculous part isn’t that a bank is suing someone for under four grand — that happens every day in America. No, the real comedy is in the details. The statement warns Tangela that if she only pays the minimum, it’ll take 13 years to pay off the balance — and she’ll end up shelling out nearly $8,700 in total. That’s a pyramid scheme disguised as a credit card. And yet, the bank isn’t offering her a payment plan, a settlement, or even a polite “hey, let’s talk.” They went straight to litigation. Meanwhile, the account was already over its credit limit, in “restricted status,” and not available for use — meaning Tangela couldn’t even keep charging to dig herself deeper. She was already frozen out, and the bank still decided to sue. It’s like locking someone out of the store and then billing them for the candy they stole last week.

And let’s not ignore the irony: Bank of America, a company that received a $45 billion taxpayer bailout during the 2008 financial crisis, is now suing an individual for failing to pay back a high-interest loan — a loan that likely helped keep her afloat during lean times. The power imbalance is staggering. One side has a legal team, a corporate budget, and the full weight of the financial system behind it. The other side? Probably just hoping this goes away if she ignores it long enough. But it won’t. Because in America, debt doesn’t die — it just gets filed, served, and litigated.

So where do we stand? We’re not rooting for Tangela to win because she dodged responsibility — she did sign a contract, after all. But we’re also not cheering for a multinational bank to squeeze every last dollar from someone who may already be struggling. The real villain here isn’t Tangela, and it’s not even Bank of America — it’s the system that turns personal financial hardship into a legal battlefield. A system where a $3,700 debt becomes a court case, where interest rates are sky-high, and where the only winners are the lawyers collecting fees on both sides. If there’s a lesson here, it’s this: don’t max out your credit card. And if you do, pray the bank doesn’t care enough to sue. Because sometimes, the cost of convenience isn’t just interest — it’s a summons in the mail.

Case Overview

$3,724 Demand Petition

Jurisdiction

District Court of Tulsa County, Oklahoma

Filing Attorney

Ashton Dewayne Sears

Nelson and Kennard, LLP

Relief Sought

$3,724 Monetary

Plaintiffs

BANK OF AMERICA, N.A. business
Rep: Nelson and Kennard, LLP

Defendants

TANGELA EKHOFF individual

Claims

#	Cause of Action	Description
1	breach of contract	failure to make required monthly payments on a credit account

Petition Text

2,336 words

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA BANK OF AMERICA, N.A., Plaintiff, vs. TANGELA EKHOFF Defendant(s). Case No. PETITION COMES NOW the Plaintiff, by and through counsel, Nelson and Kennard, LLP, and herewith alleges the following and seeks redress as hereafter delineated. 1. Plaintiff is a national banking association, which transacts business within the State of Oklahoma. 2. Venue is proper in this County, as the Defendant(s) reside(s) in this County at the commencement of this action. 3. The last four (4) digits of the Defendant’s account number, used by the current creditor as of the date of default are XXXXXXXXXXXXX8473. 4. Plaintiff's claim arises when the Defendant(s) opened a credit account and failed to make the required monthly payments as agreed. The credit account charged off for non-payment on 7/31/24, the balance due at time of default was $3,848.97. A true and accurate copy of the last periodic statement provided to the Defendant(s) prior to charge-off is attached hereto as Exhibit 1. 5. The Defendant(s) breached the Contract by failing to make the required periodic payments. 6. As a direct and proximate result of the Defendant(s) default, the total amount of debt claimed is $3,723.97. 7. The date of the last payment made by the Defendant(s) is December 6, 2024. 8. Plaintiff seeks court costs, and for such further relief as the Court may deem proper in the premises. WHEREFORE, Plaintiff, BANK OF AMERICA, N.A. prays for judgment against the Defendant(s), TANGELA EKHOFF in the amount of $3,723.97, plus all costs herein expended, including but not limited to, court costs, sheriff's fees, and special process server fees; and for such other and further relief as the Court may deem proper in the premises. Dated this January 8, 2026 Nelson and Kennard, LLP By: [signature] Ashton Dewayne Sears, OBA # 35737 12596 W. Bayaud Ave., Ste. 120 Lakewood, CO 80228 Phone: 866-920-2295 [email protected] Attorney for the Plaintiff EXHIBIT 1 BANK OF AMERICA P.O. BOX 15284 WILMINGTON, DE 19850 TANGELA EKHOFF 564 E 48TH ST N TULSA OK 74126-3262 Customer Service Information: www.bankofamerica.com 1.800.421.2110 Mail billing inquiries to: Bank of America P.O. Box 672050 Dallas TX 75267-2050 Mail payment to: Bank of America P.O. Box 851001 Dallas TX 75285-1001 Account Summary/Payment Information Previous Balance $3,760.70 Payments and Other Credits $0.00 Purchases and Adjustments $0.00 Fees Charged $0.00 Interest Charged $88.27 New Balance Total $3,848.97 Total Credit Line $3,000.00 Total Credit Available $0.00 Cash Credit Line $300.00 Portion of Credit Available for Cash $0.00 Statement Closing Date 07/27/2024 Days in Billing Cycle 30 New Balance Total $3,848.97 Current Payment Due $125.00 Past Due Amount $1,017.00 Total Minimum Payment Due $1,142.00 Payment Due Date 08/24/2024 Late Payment Warning: If we do not receive your Total Minimum Payment by the date listed above, you may have to pay a late fee of up to $40.00 and your APRs may be increased up to the Penalty APR of 29.99%. Total Minimum Payment Warning: If you make only the Total Minimum Payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: <table> <tr> <th>If you make no additional charges using this card and each month you pay</th> <th>You will payoff the balance shown on this statement in about</th> <th>And you will end up paying an estimated total of</th> </tr> <tr> <td>Only the Total Minimum Payment</td> <td>13 years</td> <td>$8,729.00</td> </tr> </table> If you would like information about credit counseling services, call 866.300.5238. BANK OF AMERICA P.O. BOX 851001 DALLAS TX 75285-1001 TANGELA EKHOFF 564 E 48TH ST N TULSA OK 74126-3262 Visa Signature® Account# [REDACTED] 8473 June 28 - July 27, 2024 Account Number: [REDACTED] 8473 Payment Due Date 08/24/2024 New Balance Total $3,848.97 Total Minimum Payment Due $1,142.00 Enter payment amount $ For change of address/phone number, see reverse side. Make your payment online at www.bankofamerica.com or Mail this coupon along with your check payable to: Bank of America IMPORTANT INFORMATION ABOUT THIS ACCOUNT PAYING INTEREST - We will not charge interest on Purchases on the next statement if you pay the New Balance Total in full by the Payment Due Date, and you had paid in full by the previous Payment Due Date. We will begin charging interest on Balance Transfers and Cash Advances on the transaction date. TOTAL INTEREST CHARGE COMPUTATION - Interest Charges accruing and are compounded on a daily basis. To determine the Interest Charges, we multiply each Balance Subject to Interest Rate by its applicable Daily Periodic Rate and that result is multiplied by the number of days in the billing cycle. To determine the total Interest Charge for the billing cycle, we add the Periodic Rate Interest Charges together. A Daily Periodic Rate is calculated by dividing an Annual Percentage Rate by 365. HOW WE ALLOCATE YOUR PAYMENTS - Payments are allocated to posted balances. If your account has balances with different APRs, we will allocate the amount of your payment equal to the Total Minimum Payment Due to the lowest APR balances first (including transactions made after this statement). Payment amounts in excess of your Total Minimum Payment Due will be applied to balances with higher APRs before balances with lower APRs. IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE - When using the optional Pay-by-Phone service, you authorize us to initiate an electronic payment from your account at the financial institution you designate. You must authorize the amount and timing of each payment. For your protection, we will ask for security information. To cancel, call us before the scheduled payment date. Same-day payments cannot be edited or canceled. YOUR CREDIT LINES - The Total Credit Line is the amount of credit available for the account; however, only a portion of that is available for Bank Cash Advances. The Cash Credit Line is that amount you have available for Bank Cash Advances. Generally, Bank Cash Advances consist of ATM Cash Advances, Over-the-Counter (OTC) Cash Advances, Same-Day Online Cash Advances, Overdraft Protection Cash Advances, Cash Equivalents, and applicable transaction fees. MISCELLANEOUS - Promotional Rate End Date: This date is based on a future statement closing date. If you change your payment due date, this date could change. The New Balance Total which appears on this statement is not a payoff amount and may be subject to additional interest charges when you pay in full after your statement closing date. Virtual cards are the digital form of your eligible physical credit cards stored within a digital wallet. CALCULATION OF BALANCES SUBJECT TO INTEREST RATE Average Daily Balance Method (including new Purchases): We calculate separate Balances Subject to an Interest Rate for Purchases and for each Introductory or Promotional Offer balance consisting of Purchases. We do this by: (1) calculating a daily balance for each day in the billing cycle; (2) adding all the daily balances together; and (3) dividing the sum of the daily balances by the number of days in the billing cycle. To calculate the daily balance for each day in this statement’s billing cycle, we: (1) take the beginning balance; (2) add an amount equal to the applicable Daily Periodic Rate multiplied by the previous day’s daily balance; (3) add new Purchases, new Account Fees, and new Transaction Fees; and (4) subtract applicable payments and credits. If any daily balance is less than zero we treat it as zero. Average Balance Method (including new Balance Transfers and new Cash Advances): We calculate separate Balances Subject to an Interest Rate for Balance Transfers, Cash Advances, and for each Introductory or Promotional Offer balance consisting of Balance Transfers or Cash Advances. We do this by: (1) calculating a daily balance for each day in this statement’s billing cycle; (2) calculating a daily balance for each day prior to this statement’s billing cycle that had a “Pre-Cycle balance” - a Pre-Cycle balance is a Balance Transfer or a Cash Advance with a transaction date prior to this statement’s billing cycle but with a posting date within this statement’s billing cycle; (3) adding all the daily balances together; and (4) dividing the sum of the daily balances by the number of days in this statement’s billing cycle. To calculate the daily balance for each day in this statement’s billing cycle, we: (1) take the beginning balance; (2) add an amount equal to the applicable Daily Periodic Rate multiplied by the previous day’s daily balance; (3) add new Balance Transfers, new Cash Advances and Transaction Fees; and (4) subtract applicable payments and credits. If any daily balance is less than zero we treat it as zero. To calculate a daily balance for each day prior to this statement’s billing cycle that had a Pre-Cycle balance: (1) we take the beginning balance attributable solely to Pre-Cycle balance (which will be zero on the transaction date of the first Pre-Cycle balance); (2) add an amount equal to the applicable Daily Periodic Rate multiplied by the previous day’s daily balance; (3) and add only the applicable Pre-Cycle balances and their related Transaction Fees. We exclude from this calculation all transactions posted in previous billing cycles. PAYMENTS - We credit mailed payments as of the date received, if the payment is: (1) received by 5 p.m. local time at the address shown on the remittance portion of your monthly statement; (2) paid with a check drawn in U.S. dollars on a U.S. financial institution or a U.S. dollar money order; and (3) sent in the return envelope with only the remittance portion of your statement accompanying it. Payments received by mail after 5 p.m. local time at the remittance address on any day including the Payment Due Date, but that otherwise meet the above requirements, will be credited as of the next day. Payments made online or by phone will be credited as of the date of receipt if made by 11:59 p.m. ET. Credit for any other payments may be delayed up to five days. Cash payments made with our tellers will only be accepted with a valid identification (ID). No payment shall operate as an accord and satisfaction without the prior written approval of one of our Senior Officers. We process most payment checks electronically by using the Information found on your check. Each check authorizes us to create a one-time electronic funds transfer (or process it as a check or paper draft). Funds may be withdrawn from your account as soon as the same day we receive your payment. Checks are not returned to you. If you have authorized us to pay your bill automatically from your savings or checking account with us, you can stop the payment on any amount you think is wrong. To stop payment, your letter must reach us at least three business days before the automatic payment is scheduled to occur. For the complete terms and conditions of your account, consult your Credit Card Agreement. This account is issued and administered by Bank of America. Bank of America is a registered trademark of Bank of America Corporation. © 2024 Bank of America Corporation Transactions <table> <tr> <th>Transaction Date</th> <th>Posting Date</th> <th>Description</th> <th>Reference Number</th> <th>Account Number</th> <th>Amount</th> <th>Total</th> </tr> <tr> <td colspan="6">Interest Charged</td> <td></td> <td></td> </tr> <tr> <td>07/27</td> <td>07/27</td> <td>INTEREST CHARGED ON PURCHASES</td> <td></td> <td></td> <td>88.27</td> <td></td> </tr> <tr> <td>07/27</td> <td>07/27</td> <td>INTEREST CHARGED ON BALANCE TRANSFERS</td> <td></td> <td></td> <td>0.00</td> <td></td> </tr> <tr> <td>07/27</td> <td>07/27</td> <td>INTEREST CHARGED ON DIR DEP&CHK CASHADV</td> <td></td> <td></td> <td>0.00</td> <td></td> </tr> <tr> <td>07/27</td> <td>07/27</td> <td>INTEREST CHARGED ON BANK CASH ADVANCES</td> <td></td> <td></td> <td>0.00</td> <td></td> </tr> <tr> <td colspan="6">TOTAL INTEREST CHARGED FOR THIS PERIOD</td> <td>$88.27</td> </tr> </table> <table> <tr> <td>Total fees charged in 2024</td> <td>$240.00</td> </tr> <tr> <td>Total interest charged in 2024</td> <td>$566.40</td> </tr> </table> Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. <table> <tr> <th>Type of Balance</th> <th>Annual Percentage Rate</th> <th>Promotional Transaction Type</th> <th>Promotional Offer ID</th> <th>Promotional Rate End Date</th> <th>Balance Subject to Interest Rate</th> <th>Interest Charges by Transaction Type</th> </tr> <tr> <td>Purchases</td> <td>28.24%V</td> <td></td> <td></td> <td></td> <td>$ 3,803.19</td> <td>$ 88.27</td> </tr> <tr> <td>Balance Transfers</td> <td>28.24%V</td> <td></td> <td></td> <td></td> <td>$ 0.00</td> <td>$ 0.00</td> </tr> <tr> <td>Direct Deposit and Check Cash Advances</td> <td>29.99%V</td> <td></td> <td></td> <td></td> <td>$ 0.00</td> <td>$ 0.00</td> </tr> <tr> <td>Bank Cash Advances</td> <td>29.99%V</td> <td></td> <td></td> <td></td> <td>$ 0.00</td> <td>$ 0.00</td> </tr> </table> APR Type Definitions Daily Interest Rate Type: V= Variable Rate (rate may vary) Important Messages You're a valued customer and we want you to know that we haven't received your current payment due. Please send your payment due today. If you've already mailed it, thank you. Your statement balance exceeds the Total Credit Line. To ensure uninterrupted use of your account, please make a payment to bring your balance under the Total Credit Line. There is no fee for being over your Total Credit Line. When this statement was created, the account's Credit Line was in a restricted status and not available for use. You can request a copy of this statement in either Braille or Large Print by calling 800.432.1000 or going to bankofamerica.com and enter Visually Impaired Access from the home page. Your Reward Summary <table> <tr> <th>.00 BASE EARNED THIS MONTH</th> </tr> <tr> <th>.00 TOTAL AVAILABLE</th> </tr> </table> Make the most of your rewards program today! How are we doing? Your opinion is important to us. You're invited to join the Bank of America® Advisory Panel and share what you think we're doing right — and what we need to do better. Enter code CACC at bankofamerica.com/AdvisoryPanel to learn more and join. When you use the QRC feature, certain information is collected from your mobile device for business purposes Inclusion on the Advisory Panel subject to qualifications.