Goodrich v. Bank of America, N.A.

CourtDistrict Court, District of Columbia
DecidedMay 19, 2022
DocketCivil Action No. 2021-1344
StatusPublished

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

Bluebook
Goodrich v. Bank of America, N.A., (D.D.C. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ROBERT D. GOODRICH, individually and in his capacity as trustee of the Robert D. Goodrich Revocable Trust,

Plaintiff, No. 21-cv-01344 (DLF) v.

BANK OF AMERICA, N.A. et al.,

Defendants.

MEMORANDUM OPINION

Robert D. Goodrich, individually and in his capacity as trustee of the Robert D. Goodrich

Revocable Trust, brings this action against Bank of America, N.A. and one of its employees

Matthew Lettinga. Goodrich alleges that the defendants breached a fiduciary duty owed to him,

committed gross negligence, and violated the District of Columbia Securities Act. See Compl.

¶¶ 19–30, Dkt. 1-2. Before this Court is the defendants’ Motion to Dismiss, Dkt. 6. For the

reasons that follow, the Court will grant the motion in part and deny it in part.

I. BACKGROUND

In 2014, Goodrich hired Bank of America to provide private wealth management services

for assets titled in both his name and the name of his revocable trust. See Compl. ¶ 7. Goodrich

deposited “virtually all of his savings and investible assets” with the bank and paid regular

investment management fees. Id. ¶¶ 7, 8. In return, Bank of America agreed to “manage all

aspects of Goodrich’s financial well-being and provide investment advice on a discretionary

basis consist[ent] with Goodrich’s investment objectives, tolerance for risk, time horizon and

financial status.” Id. ¶ 7. The bank defined Goodrich’s investment objective as “capital appreciation” with a time horizon “in excess of ten years” and determined that he had “no short-

term cash flow needs from his investment accounts.” Id. ¶ 10. Goodrich “routinely

communicated with his team of [Bank of America] financial professionals” and received

monthly statements from Bank of America regarding his investment accounts. Id. ¶¶ 8, 10.

Based on Bank of America’s advice, Goodrich opened two lines of credit with the bank.

See id. ¶ 9. These lines of credit, which were collateralized by Goodrich’s investment accounts,

allowed him to pay taxes and other expenses without making withdrawals from his investment

accounts. See id. Bank of America advised Goodrich that this strategy would “result in better

performance of his investment accounts,” which in turn would cover interest payments and

expenses associated with the lines of credit. Id.

In March 2020, as COVID-19 impacted financial markets around the world, Goodrich

became concerned about the performance of his investment accounts. See id. ¶ 11. On March

23, Goodrich called Lettinga, a portfolio manager for Bank of America with whom Goodrich had

previously communicated regarding his accounts. See id. Lettinga told Goodrich that his

investments “lost significant value due to the negative impact [of] COVID-19.” Id. ¶ 12.

Goodrich “expressed his concerns” that his investments would continue to lose value and “his

desire to protect his investment accounts by going into cash.” Id. Lettinga informed Goodrich

that “he did not believe in trying to ‘time’ the financial markets.” Id. Goodrich alleges,

however, that Lettinga later “exercised his discretionary investment authority and sold virtually

all of [his] investments.” Id.

Following these transactions, Goodrich inquired about the reinvestment of his assets. See

id. ¶ 17. Initially, Lettinga told Goodrich that “he did not feel it was the appropriate time to

reinvest.” Id. But in June 2020, Goodrich learned that due to the collateral requirements of his

2 lines of credit, the defendants could only reinvest a limited amount of Goodrich’s assets in equity

securities. See id. ¶ 18. Neither Bank of America nor Lettinga had informed Goodrich, before

selling almost all his investments, that the collateral requirements on his account would restrict

his reinvestment opportunities. See id. ¶ 13–14. If they had done so, Goodrich states that he

would have “prohibited the liquidation of his investment portfolio.” Id. ¶ 14. Ultimately,

Goodrich argues that the above transactions caused him to sustain “losses of approximately $2

million.” Id. ¶ 15.

Goodrich filed a civil action on March 19, 2021 in the Superior Court of the District of

Columbia. See Compl. In Count I, Goodrich alleges that the defendants breached their fiduciary

duty and committed gross negligence. See id. ¶¶ 19–24. In Count II, Goodrich alleges that the

defendants violated Sections 31-5605.02 and 31-5606.05 of the District of Columbia Securities

Act. See id. ¶¶ 25–30; Pl.’s Opp’n to Defs.’ Mot. to Dismiss at 22, Dkt. 12. On May 17, 2021,

the defendants removed the case to this Court. See Notice of Removal, Dkt. 1. The defendants

now move to dismiss all claims for failure to state a claim upon which relief can be granted. See

Defs.’ Mot. to Dismiss, Dkt. 6. That motion is now ripe for review.

II. LEGAL STANDARD

Rule 12(b)(6) of the Federal Rules of Civil Procedure allows a defendant to move to

dismiss a complaint for failure to state a claim upon which relief can be granted. Fed. R. Civ. P.

12(b)(6). To survive a Rule 12(b)(6) motion, a complaint must contain factual matter sufficient

to “state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544,

570 (2007). A facially plausible claim is one that “allows the court to draw the reasonable

inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S.

662, 678 (2009). This standard does not amount to a specific probability requirement, but it does

3 require “more than a sheer possibility that a defendant has acted unlawfully.” Id.; see

also Twombly, 550 U.S. at 555 (“Factual allegations must be enough to raise a right to relief

above the speculative level.”). A complaint need not contain “detailed factual allegations,” but

alleging facts that are “merely consistent with a defendant's liability . . . stops short of the line

between possibility and plausibility.” Iqbal, 556 U.S. at 678 (internal quotation marks omitted).

Well-pleaded factual allegations are “entitled to [an] assumption of truth,” id. at 679, and

the court construes the complaint “in favor of the plaintiff, who must be granted the benefit of all

inferences that can be derived from the facts alleged,” Hettinga v. United States, 677 F.3d 471,

476 (D.C. Cir. 2012) (internal quotation marks omitted). The assumption of truth does not apply,

however, to a “legal conclusion couched as a factual allegation.” Iqbal, 556 U.S. at 678

(quotation marks omitted). An “unadorned, the defendant-unlawfully-harmed-me accusation” is

not credited; likewise, “[t]hreadbare recitals of the elements of a cause of action, supported by

mere conclusory statements, do not suffice.” Id. Ultimately, “[d]etermining whether a

complaint states a plausible claim for relief [is] a context-specific task that requires the reviewing

court to draw on its judicial experience and common sense.” Id. at 679.

III. ANALYSIS

The defendants move to dismiss Goodrich’s complaint for five reasons. First, they argue

that Goodrich cannot state a claim for the breach of a fiduciary duty because he did not allege the

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