Heitsch v. JPMorgan Chase Bank, N.A.

CourtDistrict Court, E.D. Michigan
DecidedMarch 14, 2025
Docket2:24-cv-10443
StatusUnknown

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

Bluebook
Heitsch v. JPMorgan Chase Bank, N.A., (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Jennifer Heitsch,

Plaintiff, Case No. 24-cv-10443

v. Judith E. Levy United States District Judge JPMorgan Chase Bank, N.A., Mag. Judge Curtis Ivy, Jr. Defendant.

________________________________/

OPINION AND ORDER OVERRULING PLAINTIFF’S OBJECTIONS [16], OVERRULING DEFENDANT’S OBJECTION [15], AND ADOPTING THE MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION [14]

On September 23, 2024, Magistrate Judge Curtis Ivy, Jr. issued a Report and Recommendation (“R&R”) (ECF No. 14) recommending the Court grant in part and deny in part Defendant JPMorgan Chase Bank, N.A.’s motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) and/or 12(b)(7). (ECF No. 6.) Plaintiff Jennifer Heitsch filed two objections to the R&R (ECF No. 16), and Defendant responded. (ECF No. 18.) In addition, Defendant filed one objection to the R&R. (ECF No. 15.) Plaintiff responded to that objection (ECF No. 17), Defendant replied (ECF No. 19), and Plaintiff filed a document that appears to be a sur-reply.1 (ECF No. 20.) For the reasons set forth below, the parties’

objections (ECF Nos. 15, 16) are OVERRULED. The R&R (ECF No. 14)

1 In the document that appears to be a sur-reply—which is titled “Plaintiff’s Reply to Defendant’s Responses to Plaintiff’s Objections to Report and Recommendation . . .”—Plaintiff argues that

[t]he Court should not consider [Defendant’s] Reply and strike it from the record since it is not permitted by the Local Rules or the Court Rules. To the extent that the Court is going to consider the Defendant’s Reply; out of fairness to the parties, it should consider the following Reply as well.

(ECF No. 20, PageID.376.) Plaintiff is incorrect that there is no rule that allows a party to file a reply in support of an objection to a report and recommendation. Eastern District of Michigan Local Rule 72.1(d)(4) states that “[a] person may file a reply brief within 7 days of service of a response” to objections. E.D. Mich. LR 72.1(d)(4). It was therefore permissible for Defendant to file its reply, and the reply was filed within the time frame specified by Local Rule 72.1(d)(4). (See ECF Nos. 17, 19.) Plaintiff, however, did not file a reply in support of her objections that complies with Local Rule 72.1(d)(4), given that her “Reply” (1) addresses Defendant’s objection (not her own objections) and (2) was filed nine days after Defendant’s response to her objections. (See ECF Nos. 18, 20.) As a result, Plaintiff’s filing seems to be a sur-reply opposing Defendant’s objection. The Court’s Practice Guidelines provide that “[s]ur-replies are not permitted unless new law has emerged since the response was filed.” See Judge Judith E. Levy, United States District Court for the Eastern District of Michigan, https://www.mied.uscourts.gov/index.cfm?pageFunction=chambers&judgeid=44. Plaintiff has not indicated to the Court that the emergence of new law justifies the filing of a sur-reply. The Court nevertheless considers the document that she refers to as her “Reply.” (ECF No. 20.) The Court also considers Defendant’s properly filed reply. (ECF No. 19.) is ADOPTED, and Defendant’s motion to dismiss (ECF No. 6) is GRANTED IN PART AND DENIED IN PART.

I. Background The factual and procedural background set forth in the R&R is

fully adopted as though set forth in this Opinion and Order. II. Legal Standard A party may object to a magistrate judge’s report and

recommendation on a dispositive motion, and a district judge must resolve proper objections under a de novo standard of review. See 28 U.S.C. § 636(b)(1)(B)–(C); Fed. R. Civ. P. 72(b)(1)–(3). “For an objection

to be proper, Eastern District of Michigan Local Rule 72.1(d)(1) requires parties to ‘specify the part of the order, proposed findings, recommendations, or report to which [the party] objects’ and to ‘state

the basis for the objection.’” Pearce v. Chrysler Grp. LLC Pension Plan, 893 F.3d 339, 346 (6th Cir. 2018). Objections that restate arguments already presented to the magistrate judge are improper, see Coleman-

Bey v. Bouchard, 287 F. App’x 420, 422 (6th Cir. 2008) (citing Brumley v. Wingard, 269 F.3d 629, 647 (6th Cir. 2001)), as are those that are vague and dispute the general correctness of the report and recommendation, see Miller v. Currie, 50 F.3d 373, 380 (6th Cir. 1995).

Moreover, objections must be clear so that the district court can “discern those issues that are dispositive and contentious.” Id. (citing

Howard v. Sec’y of Health & Human Servs., 932 F.2d 505, 509 (6th Cir. 1991)); see also Thomas v. Arn, 474 U.S. 140, 147 (1985) (explaining that objections must go to “factual and legal” issues “at the heart of the

parties’ dispute”). In sum, the objections must be clear and specific enough to permit the Court to squarely address them on the merits. See Pearce, 893 F.3d at 346.

III. Analysis The R&R recommends that Defendant’s Motion to Dismiss (ECF No. 6) be GRANTED IN PART, DENIED IN PART. Count I (breach of contract) should remain, but Count II (Michigan’s EPIC [Estates and Protected Individuals Code] transfer of death Acts) and Count III ([common-law and statutory] conversion) [should] be DISMISSED. The [R&R] also suggests that Defendant be given an opportunity to more fully brief its motion for Rule 12(b)(7) dismissal/Rule 192 joinder. (ECF No. 14, PageID.314 (emphasis in original).)

2 References to “Rule 19” in this Opinion and Order are to Federal Rule of Civil Procedure 19. Defendant objects to the R&R’s analysis of the breach-of-contract claim in Count I. (ECF No. 15.) Plaintiff objects to the R&R’s

recommendation to dismiss the conversion claims in Count III. (ECF No. 16, PageID.328–332.) In addition, Plaintiff objects to certain

language in the R&R’s section on Rule 12(b)(7) and joinder of necessary parties. (Id. at PageID.333–334.) The Court addresses each objection below. The Court finds that the parties’ objections fail.

A. Defendant’s Objection to the R&R’s Analysis of the Breach-of-Contract Claim in Count I Defendant objects to the R&R’s analysis of the breach-of-contract claim in Count I “insofar as the [R&R] concludes that there is a conflict between the signature cards for the Accounts attached to the complaint,

and the electronic records for the Accounts [attached to Defendant’s motion] which identify the beneficiaries.” (ECF No. 15, PageID.319.) Defendant argues that “[t]here is nothing on those cards to suggest that

every beneficiary is identified thereon.” (Id. at PageID.323.) This argument does not demonstrate that there is an error in the R&R. The R&R agrees with Defendant that “the signature cards do not

purport to identify all beneficiaries.” (ECF No. 14, PageID.301.) The R&R goes on to state that “the opposite is also true—the cards do not make clear that they are not intended to list all beneficiaries, that there may be more beneficiaries than named on the card.” (Id.

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