Bullock v. American Express Executive Customer Care

• Court: District Court, District of Columbia
• Decided: April 29, 2025
• Docket: Civil Action No. 2025-0683
• Status: Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

RYISHA BULLOCK, ) ) Plaintiff, ) ) v. ) Civil Action No. 25-0683 (UNA) ) AMERICAN EXPRESS EXECUTIVE ) CUSTOMER CARE, ) ) Defendant. )

MEMORANDUM OPINION

This matter is before the Court on Plaintiff’s application to proceed in forma pauperis

and pro se complaint, as amended. The application will be granted, and the complaint will be

dismissed for lack of subject matter jurisdiction.

Plaintiff alleges that she applied for an American Express card, that Defendant denied the

application, and that, by providing her social security number on the application, the parties

“entered into a fiduciary relationship.” Compl., Ex. (ECF No. 1-1) at 5. Plaintiff declares

herself a “Secured Party Creditor with vested interests in financial agreements improperly

utilized by AMEX.” Id., Ex. at 1; see Am. Compl. (ECF No. 3) at 1. According to Plaintiff,

Defendant breached its fiduciary and contractual obligations to its cardholders, see, e.g., Compl.,

Ex. at 1-2, 4; Am. Compl. at 1, for which, among other relief, see Compl. at 4; id., Ex. at 2-3;

Am. Compl. at 2, she demands “issuance of unlimited credit cards to the Plaintiff and related

parties,” Am. Compl. at 2, and an award of $250,000, see Compl. at 4.

“Article III of the United States Constitution limits the judicial power to deciding ‘Cases

and Controversies.’” In re Navy Chaplaincy, 534 F.3d 756, 759 (D.C. Cir. 2008) (quoting U.S.

Const. art. III, § 2), cert. denied, 556 U.S. 1167 (2009). “One element of the case-or-controversy

1 requirement is that plaintiffs must establish that they have standing to sue.” Comm. on Judiciary

of U.S. House of Representatives v. McGahn, 968 F.3d 755, 762 (D.C. Cir. 2020) (citations and

internal quotation marks omitted). A party has standing for purposes of Article III if she has “(1)

suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant,

and (3) that is likely to be redressed by a favorable judicial decision.” Id. at 763 (quoting Lujan

v. Defenders of Wildlife, 504 U.S. 555, 560 (1992)).

Plaintiff’s claims are premised upon a cardholder agreement, yet the complaint’s factual

allegations demonstrate that Plaintiff is not a cardholder. Defendant neither issued Plaintiff a

credit card nor established any other business relationship with her. Missing from the complaint

are any factual allegations showing that Plaintiff sustained (or is likely to sustain) an injury

resulting from Defendant’s conduct. Because Plaintiff fails to allege facts sufficient to establish

standing, the Court lacks subject matter jurisdiction over her claims. An Order is issued

separately.

/s/ TANYA S. CHUTKAN United States District Judge DATE: April 29, 2025