Nearly every complaint alleging violations of the West Virginia Consumer Credit Protection Act includes common law causes of action, such as negligence. In a recent case, Daniels v. JP Morgan Chase & Co., Civil Action No. 2011-cv-00045 [Document 24], the Southern District dismissed these causes of action because they were not independent from the alleged violations of the WVCCPA and therefore could not proceed pursuant to the West Virginia Supreme Court of Appeals’ Decision in Casillas v. Tuscarora Land Co., 412 S.E.2d 792 (W. Va. 1991). Casillas stands for the proposition that common law causes of action based upon conduct that allegedly violates the WVCCPA may not proceed unless there are facts independent from the alleged WVCCPA violations that support the common law causes of action.