Jason-Lamar Eustache v. Discover Financial Services

District Court, N.D. New York·Decided September 8, 2026·No. 1:26-cv-01430·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK _____________________________________________________________________ Jason-Lamar Eustache,

Plaintiff, v. 1:26-CV-1430 (MAD/MJK)

Discover Financial Services,

Defendants. _____________________________________________________________________ Jason-Lamar Eustache, pro se

Mitchell J. Katz, U.S. Magistrate Judge

To the Honorable Mae A. D’Agostino, U.S. District Court Judge ORDER and REPORT-RECOMMENDATION Eustache commenced this action on July 24, 2026, by filing a Complaint. (Dkt. 1). On July 24 2026, Eustache filed an application to proceed in forma pauperis (“IFP” Application). (Dkt. 2). The Clerk has sent the Complaint and IFP Application to the Court for review. I. IFP APPLICATION Eustache declares in his IFP application that he is unable to pay the filing fee. (Dkt. 3). After reviewing Eustache’s application, this Court finds that he is eligible for IFP status. II. BACKGROUND The Court assumes familiarity with the facts of this case which

will be incorporated in the Court’s analysis where necessary. III. STANDARD OF REVIEW

Courts must consider the sufficiency of the allegations set forth in the Complaint under 28 U.S.C. §§ 1915(e)(2) and 1915A. Section 1915(e)(2) of Title 28 of the United States Code directs that, when a

plaintiff seeks to proceed IFP, “the court shall dismiss the case at any time if the court determines that – . . . (B) the action . . . (i) is frivolous or malicious; (ii) fails to state a claim on which relief may be granted; or

(iii) seeks monetary relief against a defendant who is immune from such relief.” 28 U.S.C. § 1915(e)(2). Similarly, under 28 U.S.C. § 1915A, a court must review any

“complaint in a civil action in which a prisoner seeks redress from a governmental entity or officer or employee of a governmental entity” and must “identify cognizable claims or dismiss the complaint, or any

portion of the complaint, if the complaint . . . is frivolous, malicious, or fails to state a claim upon which relief may be granted; or . . . seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(a)-(b). The term “prisoner” includes pretrial detainees. 28 U.S.C. § 1915A(c).

Second Circuit jurisprudence suggests that 28 U.S.C. § 1915(e)(2)(B)’s review of pro se complaints is a two-step inquiry.

At step one, courts apply the traditional special solicitude afforded to pro se plaintiffs. See, e.g., Rosa v. Doe, 86 F.4th 1001, 1007 (2d Cir. 2023). Indeed, courts are “obligated to afford a special solicitude to pro

se litigants.” Tracy v. Freshwater, 623 F.3d 90, 101 (2d Cir. 2010). “The solicitude afforded to pro se litigants takes a variety of forms. It most often consists of liberal construction of pleadings” and “motion papers.”

Id. (cleaned up). So, at step one, courts must “accept all of the facts alleged in the complaint as true and draw all inferences in the plaintiff’s favor.” White v. Schmidt, No. 22-1267, 2024 WL 1266245, at

*2 (2d Cir. 2024) (summary order) (quoting Harnage v. Lightner, 916 F.3d 138, 140-41 (2d Cir. 2019)). And once the court has done so, it must then construe the pro se submission “to raise the strongest arguments

that [it] suggest[s].” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (per curiam) (cleaned up). At step two, courts subject the liberally construed pleading to Rule 8’s pleading standard. See, e.g., Sykes v. Bank of Am., 723 F.3d 399, 403

(2d Cir. 2013) (per curiam) (citing Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2005) and Ashcroft v. Iqbal, 556 U.S. 662 (2009) when affirming a

district court’s dismissal of the plaintiff’s complaint under 28 U.S.C. § 1915); see also Edwards v. Erfe, 588 F. App’x 79, 80 (2d Cir. 2015) (summary order) (citing Sykes and affirming the District Court’s sua

sponte dismissal of a prisoner rights case); Hirsch v. Rochester City Police Dep’t, 578 F. App’x 49, 50 (2d Cir. 2014) (summary order) (same in a civil rights case); Sheehy v. Brown, 335 F. App’x 102, 103-04 (2d

Cir. 2009) (summary order) (citing Iqbal and affirming the District Court’s dismissal of a claim under 20 U.S.C. § 1915(e)(2)). While the Second Circuit has never formally stated that Rule 8’s

pleading standard applies, the Court infers that the Second Circuit has adopted that position. To arrive at this conclusion, the Court focuses on two pieces of evidence. First, the Circuit has cited Iqbal and Twombly—

which clarified Rule 8s pleading standard. See Sykes, 723 F.3d at 403. Second, the other circuit courts have authorized district courts to apply the Rule 12(b)(6) standard when reviewing claims under § 1915(e)(2)(B). See Herrera v. Agents of Pennsylvania Bd. of Prob. & Parole, 132 F.4th 248, 254 n.5 (3d Cir. 2025) (applying Rule 12(b)(6)’s standard to §

1915(e)(2)(B) review); Martin v. Duffy, 858 F.3d 239, 248 (4th Cir. 2017) (same); Hale v. King, 642 F.3d 492, 497 (5th Cir. 2011) (per curiam)

(same); Hill v. Lappin, 630 F.3d 468, 470-71 (6th Cir. 2010) (same); Coleman v. Lab. & Indus. Rev. Comm’n of Wisconsin, 860 F.3d 461, 468 (7th Cir. 2017) (same); Wilhelm v. Rotman, 680 F.3d 1113, 1121 (9th

Cir. 2012) (same); Kay v. Bemis, 500 F.3d 1214, 1217-18 (10th Cir. 2007) (same); Alba v. Montford, 517 F.3d 1249, 1252 (11th Cir. 2008) (same). Nothing in the Second Circuit’s jurisprudence leads this Court to

believe that it would break stride with eight other circuit courts. This evidence, altogether, leads this Court to believe that the Second Circuit approves of this Court’s application of Rule 12(b)(6)’s standard to §

1915(e)(2)(B) reviews after applying special solicitude to the pro se submission. When applying Rule 8 to pleadings, the Court must determine if a

claim is facially plausible. See Iqbal, 556 U.S. at 678 (2009) (citing Twombly, 550 U.S. at 570). “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.” Iqbal, 556 U.S. at 678. This means that pro se complaints,

even while liberally construed, “must plead ‘enough facts to state a claim to relief that is plausible on its face.”’ Sykes, 723 F.3d at 403

(quoting Twombly, 550 U.S. at 570). “Threadbare recitals of the elements of a cause of action, supported by mere conclusory statements, do not suffice.” Iqbal, 556 U.S. at 678. Rule 8 “demands more than an

Free access — add to your briefcase to read the full text and ask questions with AI

Jason-Lamar Eustache v. Discover Financial Services, (N.D.N.Y. 2026).

Jason-Lamar Eustache v. Discover Financial Services (Jason-Lamar Eustache v. Discover Financial Services) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Alba v. Montford
517 F.3d 1249 (Eleventh Circuit, 2008)
Sage v. Wyncoop
104 U.S. 319 (Supreme Court, 1881)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
Mitchell v. Forsyth
472 U.S. 511 (Supreme Court, 1985)
Cleavinger v. Saxner
474 U.S. 193 (Supreme Court, 1985)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Kay v. Bemis
500 F.3d 1214 (Tenth Circuit, 2007)
Tracy v. Freshwater
623 F.3d 90 (Second Circuit, 2010)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Ceparano v. Southampton Justice Court
404 F. App'x 537 (Second Circuit, 2011)
Salahuddin v. Cuomo
861 F.2d 40 (Second Circuit, 1988)
Flagler v. Trainor
663 F.3d 543 (Second Circuit, 2011)
Hernandez v. Coughlin
18 F.3d 133 (Second Circuit, 1994)