Johnson v. Geico Insurance (Auto)

CourtDistrict Court, E.D. New York
DecidedApril 23, 2025
Docket1:24-cv-04693
StatusUnknown

This text of Johnson v. Geico Insurance (Auto) (Johnson v. Geico Insurance (Auto)) is published on Counsel Stack Legal Research, covering District Court, E.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Johnson v. Geico Insurance (Auto), (E.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK --------------------------------------------------------------x DERRICK M. JOHNSON; TYNEKIA S. SMITH,

Plaintiffs, MEMORANDUM AND ORDER 24-CV-4693 (LDH) (LB) -against-

GEICO INSURANCE (AUTO); CARCASTLE DEALERSHIP; JANE DOE (OFFICE RECEPTION); JANE DOE (SHARON, INSURANCE AGENT); JOHN DOE (JAFFE FRAUDULENT AGENT),

Defendants. ---------------------------------------------------------------x LaSHANN DeARCY HALL, United States District Judge:

Plaintiffs Derrick M. Johnson and Tynekia S. Smith, appearing pro se bring this complaint against Geico Insurance (Auto), Carcastle Dealership, and three Jane and John Doe defendants (“Defendants”) alleging unfair trade practices and fraud, among other related claims. (See Compl., ECF No. 1.) Plaintiffs invoke the Court’s federal question jurisdiction and diversity jurisdiction under 28 U.S.C. §§ 1331, 1332. (Id.) Plaintiffs’ requests to proceed in forma pauperis pursuant to 28 U.S.C. § 1915 are granted. (See ECF Nos. 2, 5.) For the reasons discussed below, the complaint is dismissed without prejudice for lack of subject matter jurisdiction. BACKGROUND Plaintiffs Derrick M. Johnson (“Johnson”) and Tynekia S. Smith (“Smith”), residents of Floral Park, New York, bring this action against GEICO Insurance (Auto) (“GEICO”), Carcastle Dealership (“Carcastle”), located in Bellerose, New York and John and Jane Doe employees of GEICO and Carcastle. (Compl. at 3–4.) Plaintiffs allege that they were victims of a fraudulent automobile insurance scheme when they purchased a vehicle from Carcastle in November 2023.1

1 The complaint alleges that Plaintiffs purchased the vehicle in November 2024. (Compl. at 4.) This appears to be a typographical error, as the complaint was filed on July 3, 2024. (Id.) According to the complaint, Carcastle employees issued a fake insurance policy to Plaintiffs using a fake agent named “Jaffe.” (Id. at 4–9.) Plaintiffs allege that a real GEICO agent named “Sharon” allowed the Carcastle employees to use her insurance clearance code in the scheme. (Id.) Plaintiffs paid $1,133.00 for initial insurance coverage and continued to make payments, believing

the insurance policy was active. (Id. at 5–6.) According to Plaintiffs, they discovered the fraud when they were stopped by police during a routine checkpoint and were informed that the vehicle’s registration, which was in Smith’s name, had been suspended for lack of insurance. (Id. at 5–6.) Johnson was then issued a ticket for driving with a suspended registration. (Id.) The next day, Plaintiffs “investigate[d] the matter with the dealership” and then filed a complaint with the police department. (Id.) Thereafter, Plaintiffs were informed by the Department of Motor Vehicles that Smith’s driver’s license had also been suspended, “as [a] result of this fraud.” (Id.) Johnson was required to appear in criminal court on March 22, 2024, to “explain these facts before a judge.” (Id. at 8.) Plaintiffs allege that GEICO failed to adequately supervise its agents by allowing “some

third-party ghost agent to scam customers out of real service.” (Id. at 8–9.) Plaintiffs further allege that GEICO allowed an additional vehicle to be fraudlently added to the insurance policy without Plaintiffs’ knowledge, which resulted in increased costs to Plaintiffs. (Id. at 7.) Plaintiffs seek (1) $100,000 in compensatory damages, (2) $200,000 in punitive damages, (3) the reinstatement of Smith’s driving privileges, (4) a criminal investigation into the alleged fraud, and (5) for Carcastle’s business operations to be frozen until this action is resolved. (Id. at 8–10.) STANDARD OF REVIEW A complaint “must contain 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)). A claim is facially plausible when the alleged facts allow the court to draw a “reasonable inference” of a defendant’s liability for the alleged misconduct. Iqbal, 556 U.S. at 678. While this standard requires more than a “sheer possibility” of a defendant’s liability, id., “[i]t is not the [c]ourt’s function to weigh the evidence that might

be presented at trial” on a motion to dismiss. Morris v. Northrop Grumman Corp., 37 F. Supp. 2d 556, 565 (E.D.N.Y. 1999). Instead, “the [c]ourt must merely determine whether the complaint itself is legally sufficient, and in doing so, it is well settled that the [c]ourt must accept the factual allegations of the complaint as true.” Id. (internal citation omitted). Moreover, where, as here, a plaintiff is proceeding pro se, their pleadings “must be construed liberally and interpreted to raise the strongest arguments that they suggest.” Sykes v. Bank of Am., 723 F.3d 399, 403 (2d Cir. 2013) (quoting Triestman v. Fed. Bureau of Prisons,

470 F.3d 471, 474 (2d Cir. 2006)). A pro se complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Boykin v. KeyCorp, 521 F.3d 202, 213–14 (2d Cir. 2008) (quoting Erickson v. Pardus, 55 U.S. 89, 94 (2007) (per curiam)). This is “particularly so when the pro se plaintiff alleges that [their] civil rights have been violated.” Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 191 (2d Cir. 2008). Still, “even pro se plaintiffs asserting civil right claims cannot withstand a motion to dismiss unless their pleadings contain factual allegations sufficient to raise a ‘right to relief above the speculative level.’” Jackson v. NYS Dep’t of Labor, 709 F. Supp. 2d 218, 224 (S.D.N.Y. 2010)

(quoting Twombly, 550 U.S. at 555)). Nonetheless, a district court may dismiss a pro se action sua sponte, even if the plaintiff has paid the Court’s filing fee, if it determines that the action is frivolous or that the Court lacks subject matter jurisdiction. See Fitzgerald v. First East Seventh Street Tenants Corp., 221 F.3d 362, 363-64 (2d Cir. 2000) (affirming sua sponte dismissal of frivolous pro se complaint where pro se plaintiff had paid the required filing fee). An action is frivolous when “either (1) ‘the factual contentions are clearly baseless, such as when allegations are the product of delusion or fantasy;’ or (2) ‘the claim is based on an indisputably meritless legal theory.’” Livingston v.

Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998) (quoting Nance v. Kelly, 912 F.2d 605, 606 (2d Cir. 1990) (per curiam)). A finding of frivolousness is appropriate “when the facts alleged rise to the level of the irrational or the wholly incredible, whether or not there are judicially noticeable facts available to contradict them.” Denton v.

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Johnson v. Geico Insurance (Auto), Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-v-geico-insurance-auto-nyed-2025.