Friesel v. Bank of America, N.A

CourtDistrict Court, S.D. New York
DecidedApril 24, 2025
Docket7:24-cv-02346
StatusUnknown

This text of Friesel v. Bank of America, N.A (Friesel v. Bank of America, N.A) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Friesel v. Bank of America, N.A, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT DOCUMENT SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED DOC #: CHESKEL FRIESEL, DATE FILED: 4/24/2025 Plaintiff, -against- 24-cv-2346 (NSR) BANK OF AMERICA, N.A., JP MORGAN OPINION & ORDER CHASE, N.A., Defendants.

NELSON S. ROMAN, United States District Judge: Plaintiff Cheskel Friesel (“Friesel” or “Plaintiff’) initiated this action on March 28, 2024, asserting claims of unjust enrichment, breach of contract, negligence, and seeking the imposition of a constructive trust, against Defendant Bank of America North America and Defendant JP Morgan Chase North America (together, “Defendants”). Presently before the Court is Defendants’ Motion to Dismiss Plaintiff’s Complaint pursuant to Federal Rules of Civil Procedure 12(b)(6). For the following reasons, Defendants’ Motion to Dismiss is GRANTED without prejudice. BACKGROUND The following facts are derived from the Complaint and are taken as true and constructed in the light most favorable to the Plaintiff at this stage. PROCEDURAL HISTORY On March 28, 2024, Plaintiff commenced this action against the Defendants by filing his Complaint. (ECF No. 1.) The Defendants filed their motion to dismiss and memorandum of law in support on December 20, 2024 (“Mot.”) (ECF Nos. 14 and 15.) Plaintiff did not file an

opposition to the Defendants’ motion and thus Defendants did not file a reply in further support of their motion. Plaintiff resides at 140 Clinton Lane, a/k/a 142 Clinton Avenue, Spring Valley, New York 10977 (the “Property”). (Compl. ¶ 1.) On or about June 24, 2019 a foreclosure sale was held and

the Defendants successfully acquired the property. (Id. ¶ 5.) Since acquiring the property, Defendants have not performed repairs, maintenance, nor paid for the building’s heath and electric utilities. (Id. ¶ 6.) The building is a multifamily unit with several tenants. (Id. ¶ 7.) Since the Defendants acquired the property, Plaintiff has been entirely responsible for maintenance and upkeep, including making repairs, ensuring the property was shoveled, was with heat and had electricity. (Id. ¶¶ 8, 9.) Plaintiff has been forced to bear the expenses for the property and has functionally assumed the roles of property manager and superintendent. (Id. ¶¶ 10, 11.) Defendants did not assign anyone to take over Plaintiff’s assumed roles. (Id. ¶ 12.) JP Morgan Chase, on behalf of Bank of America, recently received money from an insurance company for the costs of the property repairs. (Id. ¶ 13.) Instead of allocating the money to conduct the necessary

repairs, the Defendants kept the proceeds for themselves. (Id. ¶ 14.) LEGAL STANDARD A. Rule 12(b)(6) Under Federal Rule of Civil Procedure 12(b)(6), dismissal is proper unless the complaint “contain[s] 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 Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). When there are well-pled factual allegations in the complaint, “a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Id. at 679. While the Court must take all material factual allegations as true and draw reasonable inferences in the non-moving party’s favor, the Court is “not bound to accept as true a legal conclusion couched as a factual allegation,” or to credit “mere conclusory statements” or “[t]hreadbare recitals of the elements of a cause of action.” Id. at 678 (quoting Twombly, 550 U.S. at 555). The Second Circuit “deem[s] a complaint to include any written instrument attached to it

as an exhibit or any statements or documents incorporated in it by reference . . . and documents that plaintiffs either possessed or knew about and upon which they relied in bringing the suit.” Rotham v. Gregor, 220 F.3d 81, 88 (2d Cir. 2000) (internal citations omitted). The critical inquiry is whether the Plaintiff has pled sufficient facts to nudge the claims “across the line from conceivable to plausible.” Twombly, 550 U.S. at 570. A motion to dismiss will be denied where the allegations “allow[] the court to draw the reasonable inference that the Defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678. DISCUSSION Plaintiff brings claims of unjust enrichment, breach of contract, negligence, and seeking the imposition of a constructive trust. The Court addresses them in turn.

A. Unjust Enrichment

Plaintiff asserts two unjust enrichment claims against the Defendants. In order to successfully state an unjust enrichment claim, a plaintiff must allege “that (1) the other party was enriched, (2) at the party’s expense, and (3) that it is against equity and good conscience to permit the other party to retain what is sought to be recovered.” Georgia Malone & Co. v. Rieder, 19 N.Y.3d 511, 973 N.E.2d 743 (2012) (internal citations omitted). Moreover, a plaintiff “cannot succeed on an unjust enrichment claim unless it has a sufficiently close relationship with the party . . . there must exist a relationship or connection between the parties that is not ‘too attenuated.’” Id. The Court must find that Plaintiff’s unjust enrichment claim fails due to the lack of a “sufficiently close relationship” between the parties. Id. The only connection between Plaintiff and the Defendants is the property; Defendants acquired the property following a foreclosure sale, and Plaintiff resides at the property and allegedly maintains it. (Compl. ¶¶ 8-10.) While this might

suggest that a relationship exists, such an indication is necessary but not sufficient to state an unjust enrichment claim. Per Georgia Malone & Co., a mere relationship is not enough – it must not be “too attenuated.” Georgia Malone & Co, 973 N.E.2d 743 (2012). As currently written, the Complaint only suggests that some relationship exists, which is “too attenuated” to successfully establish the elements of an unjust enrichment claim. Accordingly, the Court must dismiss Plaintiff’s unjust enrichment claim without prejudice. B. Breach of Contract To state a prima facie case for breach of contract under New York law, a plaintiff must show: “(1) the existence of an agreement, (2) adequate performance of the contract by the plaintiff, (3) breach of contract by the defendant, and (4) damages.” Harsco Corp. v. Segui, 91 F.3d 337,

348 (2d Cir. 1996). The “fundamental basis of a valid, enforceable contract is a meeting of the minds of the parties, and, if there is no meeting of the minds on all essential terms, there is no contract.” Benicorp Ins. Co. v. Nat'l Med. Health Card Sys., Inc., 447 F. Supp. 2d 329, 337 (S.D.N.Y. 2006). Moreover, if “the Court finds substantial ambiguity regarding whether both parties have mutually assented to all material terms, then the Court can neither find, nor enforce, a contract.” Id. Presently, Plaintiff’s breach of contract claim falls short because of Plaintiff’s failure to plead that the parties mutually assented to any agreement. Plaintiff does not plead the parties discussed an agreement wherein Plaintiff would manage the property.

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Bell Atlantic Corp. v. Twombly
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Georgia Malone & Co. v. Rieder
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Bluebook (online)
Friesel v. Bank of America, N.A, Counsel Stack Legal Research, https://law.counselstack.com/opinion/friesel-v-bank-of-america-na-nysd-2025.