Goudarzi v. JP Morgan Chase Bank NA

CourtDistrict Court, W.D. Washington
DecidedJuly 16, 2025
Docket2:24-cv-01882
StatusUnknown

This text of Goudarzi v. JP Morgan Chase Bank NA (Goudarzi v. JP Morgan Chase Bank NA) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Goudarzi v. JP Morgan Chase Bank NA, (W.D. Wash. 2025).

Opinion

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4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 MANOUCHEHR GOUDARZI et al., CASE NO. C24-1882-KKE 8

Plaintiff(s), ORDER ON MOTION TO COMPEL 9 v. ARBITRATION

10 J.P. MORGAN CHASE BANK N.A.,

11 Defendant(s).

12 Plaintiffs Manouchehr Goudarzi, Valerie Goudarzi, and Maryam Goudarzi1 (collectively, 13 “Plaintiffs”) sue Defendant J.P. Morgan Chase Bank, N.A. (“JPMC”), alleging racial 14 discrimination and violation of the Equal Credit Opportunities Act and Washington Consumer 15 Protection Act. Dkt. No. 1 at 7. 16 Defendant now moves the Court to compel Plaintiffs to arbitrate their claims. Dkt. No. 16. 17 The burden is on Defendant to demonstrate that Plaintiffs had reasonable notice of the arbitration 18 clause and assented to its terms. As detailed below, the record proffered by Defendant does not 19 carry this burden. To the contrary, the incomplete and contradictory evidence presented in support 20 of Defendant’s motion raises numerous factual issues regarding whether Plaintiffs demonstrated 21 mutual assent to the arbitration clause. More importantly, the record shows that even if an 22 23 1 For clarity, this order identifies Plaintiffs individually as “Mr. Goudarzi,” “Mrs. Goudarzi,” and “Ms. Goudarzi,” respectively. 24 1 agreement to arbitrate was formed, the arbitration clause is procedurally unconscionable and thus 2 unenforceable. For this reason, the Court denies Defendant’s motion to compel. Further, because 3 the Court determines arbitrability in this case, Defendant’s request that any discovery on these

4 issues should take place in arbitration is also denied as moot.2 5 I. BACKGROUND 6 This is a civil rights case, involving allegations of racial discrimination connected with the 7 closing of Plaintiffs’ bank accounts at JPMC. The Court sets forth the relevant facts below, most 8 of which derive from the complaint. 9 A. The December 2021 Incident and the Closing of Plaintiffs’ Accounts 10 On December 17, 2021, Mr. Goudarzi, who is Middle Eastern, visited a JPMC branch in 11 Seattle and requested a cashier’s check from his account. Dkt. No. 1 at 1–2, 3. After he presented 12 three forms of identification, the teller refused to issue him the cashier’s check without explaining 13 why. Id. at 2, 4. She photocopied his IDs without his consent. Id. Mr. Goudarzi complained, and 14 asked the other bank tellers for help, but they refused to assist him. Id. He left the branch location, 15 after which the teller reported him to the police. Id. at 5. 16 The next day, Mr. Goudarzi made a formal complaint via Defendant’s telephone hotline 17 and described the treatment he received. Dkt. No. 1 at 5. He also contacted his personal banker 18 at JPMC and told her that he felt that the teller had discriminated against him. Id. His personal 19 banker notified Mr. Goudarzi that the manager at that branch was out of town, but that she would 20 leave the manager a message. Id. On January 28, 2022, Defendant closed Mr. Goudarzi’s account 21 without notice. Id. 22

23 2 In opposition to Defendant’s motion to compel, Plaintiffs sought discovery relating to the arbitration clause. Dkt. No. 24. Defendant maintained that no discovery was needed for resolving this motion and filed a motion to stay discovery. Dkt. No. 27 at 11, Dkt. No. 29 at 5. Given the Court’s disposition of the motion to compel, Defendant’s 24 motion to stay is moot. 1 On February 1, 2022, Plaintiffs received a letter dated January 14, 2022, stating that 2 Defendant had closed Mrs. Goudarzi’s account as well. Id. at 6. Mr. Goudarzi then discovered 3 that Defendant had closed all three Plaintiffs’ accounts. Id. Over a month passed before Chase

4 provided Plaintiffs access to their funds by sending Plaintiffs a check via mail. Id. at 2. In a letter 5 dated May 11, 2022, Defendant notified Plaintiffs that it closed their accounts due to the December 6 17, 2021 incident. Id. at 6. 7 B. The Arbitration Clause 8 Plaintiffs had been longtime account holders with Defendant. Dkt. No. 1 at 3, 5–6. Mr. 9 and Mrs. Goudarzi were joint account holders on at least one JPMC account. Dkt. No. 18 at 25. 10 Ms. Goudarzi was also a joint account holder with Mr. Goudarzi. Id. at 9. 11 When customers open an account with JPMC, they are required to electronically “sign” a 12 Personal Electronic Signature Card (“signature card”). See id. at 5. There is no evidence in the

13 record explaining the process by which customers affix their electronic signature, or the 14 mechanism by which a customer would view the information contained on the card. The signature 15 card includes the following acknowledgment: 16 I acknowledge receipt of the Bank’s Deposit Account Agreement or other applicable account agreement or the Chase Liquid Agreement, which includes all 17 provisions that apply to this deposit account and/or Chase Liquid Card and the Bank Privacy Policy, and agree to be bound by the terms and conditions therein as 18 amended from time to time. Dkt. No. 18 at 5. The signature card and the acknowledgment do not include a hyperlink or web 19 address and do not indicate that any agreement referenced therein contains an arbitration clause. 20 Id. Rather, in the version of the signature cards attached to Defendant’s motion, the first page is 21 an otherwise blank page that contains the statement: “A version of the agreements and disclosures 22 that you can print and keep is available at Chase.com/Disclosures[.]” Id. at 4. Defendant does not 23 24 1 explain where a customer would have seen this statement, or how it is connected to the signing of 2 the signature card itself. See id. at 1–2. 3 In their brief, Plaintiffs contend that visiting Chase.com/Disclosures3 reveals three

4 different hyperlinks, labeled: Deposit Account Agreement (“DAA”), Additional Banking Services 5 and Fees for Personal Accounts, and Rate Sheet. Dkt. No. 24 at 6. To access the DAA, after 6 clicking on the correct hyperlink, Plaintiffs claim that customers must type in the ZIP code 7 associated with their bank account. Id. at 7. The website then navigates to another page with links 8 to both current and past-effective-date documents, including multiple versions of the DAA. Id. 9 After choosing the currently effective DAA from among other outdated versions, the customer 10 must scroll to page 14, where the arbitration clause is located. Dkt. No. 19 at 17. 11 The arbitration clause is not identified in the table of contents for the March 17, 2019 DAA, 12 which was the version in effect when Plaintiffs opened some of the subject accounts. Id. at 5; Dkt.

13 No. 18 (signature cards for accounts opened in 2019). For the DAA in effect from November 14, 14 2021 to June 11, 2022, the arbitration clause is listed in the last section of the table of contents. 15 Dkt. No. 19 at 31. This version of the DAA was in effect during the allegedly discriminatory 16 incident in December 2021, and when Defendant unilaterally closed Plaintiffs’ accounts in January 17 2022. See Dkt. No. 1 at 3–6. 18 The arbitration clause in the DAA states: 19 You and we agree that upon the election of either of us, any dispute relating in any way to your account or transactions will be resolved by binding arbitration as 20 discussed below, and not through litigation in any court (except for matters in small

21 3 Plaintiffs argue in their brief that accessing the DAA and arbitration clause online requires 10 discrete steps. Dkt. No. 24 at 7. Defendant generally disputes this characterization but does not explain how or why Plaintiffs’ recitation 22 is inaccurate. Dkt. No. 27 at 8 n.4. Neither party provides evidence in the form of screenshots or declarations describing the process of accessing the correct DAA on the Chase.com/disclosures website, which is the standard and 23 best practice. See Saeedy v. Microsoft Corp., 757 F. Supp. 3d 1172, 1192 (W.D. Wash.

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