Errato v. Bendett & McHugh, PC

CourtDistrict Court, D. Connecticut
DecidedMay 21, 2025
Docket3:23-cv-01674
StatusUnknown

This text of Errato v. Bendett & McHugh, PC (Errato v. Bendett & McHugh, PC) is published on Counsel Stack Legal Research, covering District Court, D. Connecticut primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Errato v. Bendett & McHugh, PC, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ROBERT M. ERRATO, ) Plaintiff, ) ) 3:23-cv-1674 (OAW) v. ) ) BENDETT & MCHUGH, PC, ) BROCK & SCOTT, and ) CITIZENS BANK, N.A., ) Defendants. ) RULING ON MOTIONS TO DISMISS Self-represented plaintiff Robert Errato brings this action for claims arising out of the foreclosure of his home. Am. Compl. ¶¶ 7–8, ECF No. 20. He alleges that Bendett & McHugh, PC and Brock & Scott (together the “Brock Defendants”) and Citizens Bank (collectively the “Defendants”) violated the Fair Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692 et seq., and the Connecticut Unfair Trade Practices Act (“CUTPA”), Conn. Gen. Stat. Ann. § 42–110a et seq., and committed intentional infliction of emotional distress and intentional misrepresentation. The Brock Defendants and Citizens Bank filed separate motions to dismiss, ECF Nos. 28, 29, seeking to dismiss all claims against them under Fed. R. Civ. Pro. 12(b)(1), for lack of subject matter jurisdiction, and Fed. R. Civ. Pro. 12(b)(6), for failure to state a claim upon which relief may be granted. The court has reviewed the motions, Plaintiff’s objections, ECF Nos. 32, 33, Defendants’ replies thereto, ECF Nos. 34, 35, and the record in this case. For the reasons discussed herein, the Brock Defendants’ Motion to Dismiss is GRANTED IN PART and is DENIED IN PART, and Citizens Bank’s Motion to Dismiss is GRANTED. I. BACKGROUND The following facts are taken from the amended complaint and public records that are integral to the underlying facts of the complaint. Roth v. Jennings, 489 F.3d 499, 509 (2d Cir. 2007) ("[W]here public records that are integral to a . . . complaint are not attached

to it, the court, in considering a Rule 12(b)(6) motion, is permitted to take judicial notice of those records."). These facts are accepted as true for the purpose of this motion. Plaintiff had a mortgage loan agreement with Citizens Bank for his home, located at 155 Chestnut Lane, Hamden, Connecticut (the “Hamden Property”). Am. Compl. ¶¶ 1, 10. In or around 2020, Plaintiff “fell behind on his mortgage payments.” Id. ¶ 9. Thereafter, he “[worked] with representatives from [Citizens Bank] to obtain a loan modification or some type of agreement to repair the situation.” Id. ¶ 10. Notwithstanding Plaintiff’s efforts to secure mitigation assistance, Citizens Bank initiated foreclosure proceedings against him. See id. Thereafter, Plaintiff received letters from the Brock Defendants seeking payment

on the loan. Id. ¶¶ 7, 11. On November 14, 2022, Plaintiff sent a letter back to them “in full conformity with [the FDCPA]” demanding they “cease contacting him and attempting to collect the debt.” Id. ¶ 12; see Ex. A, ECF No. 20. A copy of this letter was sent to Citizens Bank as well. Am. Compl. ¶ 12. Additionally, he sent a second letter on or around September 11, 2023, to Brock & Scott. Id. ¶ 14. Thereafter, Bendett & McHugh and Brock & Scott “continued to contact Plaintiff and continued to litigate the foreclosure action against Plaintiff.” Id. ¶ 15. The Connecticut Judicial Branch website reveals that Citizens Bank initiated foreclosure proceedings on the Hamden Property on February 21, 2023. See Citizens Bank, N.A. v. Errato et al, New Haven Judicial District, Docket No. NNH-CV23-6130431- S (Conn. Super. Ct. Feb. 21, 2023). On October 16, 2023, the Superior Court issued a judgment of foreclosure in Citizens Bank’s favor. Id. at Docket No. 124. After the foreclosure judgment was issued, Plaintiff received a letter from Citizens

Bank described as “legally required notice” informing him of options available to avoid strict foreclosure. Am. Compl. ¶ 17. The letter and accompanying documents described options that “were never presented to” Plaintiff prior to the foreclosure judgment. Id. ¶¶ 17–18. The letter was dated December 29, 2023, and was postmarked on January 5, 2024. Ex. C, ECF No. 20. Additionally, in February 2024, Plaintiff received letters from Citizens Bank indicating a representative from the bank would contact Plaintiff to discuss his “request for information regarding Foreclosure Prevention[] options.” Id. ¶ 21–22. Plaintiff initiated this action on December 26, 2023, and filed an amended complaint as of right February 26, 2024. See Compl., ECF No. 1; Am. Compl. Plaintiff claims that Defendants violated the FDCPA and CUTPA and committed intentional

infliction of emotional distress and intentional misrepresentation. Am. Compl. Count One–Count Seven. He seeks injunctive relief and damages. Id. at 15. Responding to the amended complaint, the Brock Defendants and Citizens Bank filed motions to dismiss for lack of subject matter jurisdiction and for failure to state a claim. Mem. of Law in Support of Brock Defs.’ Mot. to Dismiss the Am. Compl., ECF No. 28-1 (“Brock Defs. Mot.”); Def. Citizens Bank, N.A.’s Mem. of Law in Support of its Mot. to Dismiss Am. Compl., ECF No. 29-1 (“Bank Mot.”). Plaintiff has since moved to amend his complaint three times to add claims to his pleading. See ECF Nos. 36, 40, 44. II. LEGAL STANDARD To survive a motion to dismiss under Rule 12(b)(6), “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly,

550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. A complaint “does not need detailed factual allegations” to survive a 12(b)(6) motion to dismiss, however, “a plaintiff's obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555 (alteration and quotation marks omitted). Further, when reviewing a 12(b)(6) motion to dismiss, the court must draw all reasonable inferences in the non-movant’s favor. Sheppard v. Beerman, 18 F.3d 147, 150 (2d Cir. 1994) (internal citations omitted).

To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(1) for lack of subject matter jurisdiction, a plaintiff must prove “by a preponderance of the evidence that [subject matter jurisdiction] exists.” Makarova v. United States, 201 F.3d 110, 113 (2d Cir. 2000). If a district court lacks statutory or constitutional authority to adjudicate a case, the case must be dismissed for lack of subject matter jurisdiction under Rule 12(b)(1). Id. Finally, when a plaintiff is proceeding pro se, the district court must “read the pleadings of a pro se plaintiff liberally and interpret them ‘to raise the strongest arguments that they suggest.’” Vargas-Crispin v. Zenk, 376 F. Supp. 2d 301, 303 (E.D.N.Y. 2005) (quoting McPherson v. Coombe, 174 F.3d 276, 280 (2d Cir.1999)). Nonetheless, pro se plaintiffs still must satisfy relevant rules of procedural and substantive law. See id.

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Bluebook (online)
Errato v. Bendett & McHugh, PC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/errato-v-bendett-mchugh-pc-ctd-2025.