BATISTA v. AT&T INC.

CourtDistrict Court, D. New Jersey
DecidedJune 17, 2025
Docket2:24-cv-08503
StatusUnknown

This text of BATISTA v. AT&T INC. (BATISTA v. AT&T INC.) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
BATISTA v. AT&T INC., (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

JOSHUA BATISTA,

Civil Action No. 24-cv-8503 (JXN)(MAH) Plaintiff,

v. OPINION

AT&T INC.,

Defendant.

NEALS, District Judge: Before this Court is Defendant AT&T Inc.’s (“AT&T”) motion to dismiss pro se Plaintiff Joshua Batista’s Complaint (ECF No. 1) (“Compl.” or “Complaint”) for lack of personal jurisdiction and for failure to state a claim, pursuant to Federal Rules of Civil Procedure 8, 12(b)(1), 12(b)(2), and 12(b)(6). (ECF No. 8). The Court has carefully considered the parties’ submissions and decides this matter without oral argument under Federal Rule of Civil Procedure 78(b) and Local Civil Rule 78.1(b). For the reasons set forth below, AT&T’s motion to dismiss the Complaint (ECF No. 8) is GRANTED, and the Complaint (ECF No. 1) is DISMISSED without prejudice, except for Counts Three through Five, which are DISMISSED with prejudice. I. BACKGROUND AND PROCEDURAL HISTORY1 According to the Complaint, Plaintiff is a former employee of AT&T’s “Mobility Department” where he was employed from October 2014 to January 2024. (Compl. ¶ 6). While

1 Pro se complaints are construed liberally and are “h[e]ld to less stringent standards than formal pleadings drafted by lawyers.” Haines v. Kerner, 404 U.S. 519, 520 (1972); see also Erickson v. Pardus, 551 U.S. 89, 94 (2007). Nevertheless, pro se litigants must still allege facts, taken as true, to suggest the required elements of the claims asserted. See Phillips v. Cnty. of Allegheny, 515 F.3d 224, 234-35 (3d Cir. 2008); McNeil v. United States, 508 U.S. 106, 113 (1993) (“[W]e have never suggested that procedural rules in ordinary civil litigation should be interpreted so as to excuse mistakes by those who proceed without counsel.”). working for AT&T for nearly a decade, Plaintiff “accrued and accumulated $13,521.62 USD in a Bargained Cash Balance #2 Program of the AT&T PBP held in a Trust fund with Fidelity Investments.” (Id. at ¶ 28). Plaintiff argues AT&T refuses to release the vested funds in a single payment, as requested. (Id. at ¶ 29).

Plaintiff has also maintained an active mobile service account with AT&T since 2013, and an equipment installment plan. (Id. at ¶¶ 7, 22). Plaintiff alleges that his account is “an accounts receivable and asset backed security with [AT&T] which [AT&T] pledges as collateral to third- party investors as a means for [AT&T] to raise capital.” (Id. at ¶ 18). According to AT&T’s Form 10-K for the fiscal year ending December 31, 2023 filed with the Securities and Exchange Commission (“SEC”), AT&T states: We have agreements with various third-party financial institutions pertaining to the sales of certain types of our accounts receivable. The most significant of these programs consists of receivables arising from equipment installment plans, which are sold for cash and beneficial interests, such as deferred purchase price, when applicable. Under the terms of our agreement for this program, we continue to service the transferred receivables on behalf of the financial institutions. (Id. at ¶ 19). Plaintiff argues AT&T is unjustly enriching itself by “pooling, selling, transferring, conveying, and pledging Plaintiff’s accounts receivable, equipment installment plan and asset backed security” and “sells their consumer’s equipment installment plans for cash and beneficial interest.” (Id. at ¶¶ 20-21). Further, as an “investor” in AT&T, Plaintiff’s account is credited each month for dividend payments. (Id. at ¶¶ 24-25). According to the Complaint, AT&T has “knowingly and willingly participate[d] in extortion and peonage against Plaintiff by deceptively redeeming Plaintiff’s credits on account and demanding Plaintiff, under threat and coercion in the event of a ‘non- payment’ of debt notes (Federal Reserve Notes) to Plaintiff’s already credited account.” (Id. at ¶ 26). If Plaintiff does not pay, then AT&T “unlawfully disrupts and suspends Plaintiff’s service” and “add[s] frivolous and fraudulent charges and fees to Plaintiff’s account.” (Id. at ¶ 27). On August 16, 2024, Plaintiff filed a Complaint against AT&T. (See Compl.). In the Complaint, Plaintiff raises ten claims against AT&T: (1) breach of contract (Count One); (2) breach

of fiduciary duty (Count Two); (3) laundering of monetary instruments, 18 U.S.C. § 1956 (Count Three); (4) transportation of stolen securities, 18 U.S.C. § 2314 (Count Four); (5) securities and commodities fraud, 18 U.S.C. § 1348 (Count Five); (6) peonage, 18 U.S.C. § 1581 (Count Six); (7) enticement into slavery, 18 U.S.C. § 1583 (Count Seven); (8) sale into involuntary servitude, 18 U.S.C. § 1584 (Count Eight); (9) forced labor, 18 U.S.C. § 1589 (Count Nine); and (10) benefitting financially from peonage, slavery, and trafficking in persons, 18 U.S.C. § 1593A (Count Ten). (Id.) On October 8, 2024, AT&T filed a motion to dismiss the Complaint pursuant to Federal Rules of Civil Procedure 8, 12(b)(1), 12(b)(2), and 12(b)(3). (ECF No. 8) (“Br.”). Plaintiff opposed the motion (ECF No. 12) (“Opp’n”), to which AT&T replied. (ECF No. 13) (“Reply”).

Thereafter, on November 12, 2024, Plaintiff filed additional opposition to AT&T’s motion without leave of this Court. (ECF No. 14) (“Sur-reply”). Local Civil Rule 7.1(d)(6) states that “[n]o sur-replies are permitted without permission of the Judge to whom the case is assigned.” Given Plaintiff’s pro se status, the Court will consider the sur-reply. See Richardson v. Cascade Skating Rink, No. 19-8935, 2022 WL 2314836, at *2 n.1 (D.N.J. June 28, 2022) (considering a sur-reply filed by a pro se plaintiff without prior leave of court due to the greater leeway afforded to pro se litigants (citing Higgs v. Att’y Gen., 655 F.3d 333, 339 (3d Cir. 2011)). Accordingly, the motion is ripe for the Court to decide. II. LEGAL STANDARD A. Motion to Dismiss for Lack of Subject Matter Jurisdiction Pursuant to Rule 12(b)(1) A complaint may be dismissed for lack of subject matter jurisdiction. Fed. R. Civ. P. 12(b)(1). “Challenges to subject matter jurisdiction can be either ‘facial’ or ‘factual.’” Smolow v. Hafer, 353 F. Supp. 2d 561, 566 (E.D. Pa. 2005) (citing Mortensen v. First Fed. Sav. & Loan Ass'n, 549 F.2d 884, 891 (3d Cir. 1977)). In considering a Rule 12(b)(1) motion to dismiss, a district court must first determine whether the motion “attack[s]” (1) the complaint as deficient on its face; or (2) “the existence of subject matter jurisdiction in fact, . . . apart from any pleadings.” Mortensen, 549 F.2d at 891.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cannon Manufacturing Co. v. Cudahy Packing Co.
267 U.S. 333 (Supreme Court, 1925)
International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Shaffer v. Heitner
433 U.S. 186 (Supreme Court, 1977)
World-Wide Volkswagen Corp. v. Woodson
444 U.S. 286 (Supreme Court, 1980)
Leeke v. Timmerman
454 U.S. 83 (Supreme Court, 1982)
Keeton v. Hustler Magazine, Inc.
465 U.S. 770 (Supreme Court, 1984)
Helicopteros Nacionales De Colombia, S. A. v. Hall
466 U.S. 408 (Supreme Court, 1984)
Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Burnham v. Superior Court of Cal., County of Marin
495 U.S. 604 (Supreme Court, 1990)
Carnival Cruise Lines, Inc. v. Shute
499 U.S. 585 (Supreme Court, 1991)
McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
United States v. Bestfoods
524 U.S. 51 (Supreme Court, 1998)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Santiago v. Warminster Township
629 F.3d 121 (Third Circuit, 2010)
Goodyear Dunlop Tires Operations, S. A. v. Brown
131 S. Ct. 2846 (Supreme Court, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
BATISTA v. AT&T INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/batista-v-att-inc-njd-2025.