Jonathan Payton v. Wells Fargo Bank

CourtDistrict Court, S.D. New York
DecidedNovember 26, 2025
Docket1:25-cv-06019
StatusUnknown

This text of Jonathan Payton v. Wells Fargo Bank (Jonathan Payton v. Wells Fargo Bank) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jonathan Payton v. Wells Fargo Bank, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK JONATHAN PAYTON, Plaintiff, 25-CV-6019 (LLS) -against- ORDER OF DISMISSAL WELLS FARGO BANK, WITH LEAVE TO REPLEAD Defendant. LOUIS L. STANTON, United States District Judge: Plaintiff, who is appearing pro se, brings this action involving the court’s federal question jurisdiction, alleging that an employee at Defendant Wells Fargo Bank discriminated against him. By order dated November 5, 2025, the court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. For the reasons set forth below, the Court dismisses the complaint, but grants Plaintiff 30 days’ leave to replead his claims in an amended complaint. STANDARD OF REVIEW The Court must dismiss an IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also dismiss a complaint when the Court lacks subject matter jurisdiction of the claims raised. See Fed. R. Civ. P. 12(h)(3). While the law mandates dismissal on any of these grounds, the Court is obliged to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” in pro se cases, id. at 475 (citation omitted), has its limits – to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the

pleader is entitled to relief. Rule 8 requires a complaint to include enough facts to state a claim for relief “that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible if the plaintiff pleads enough factual detail to allow the Court to draw the inference that the defendant is liable for the alleged misconduct. In reviewing the complaint, the Court must accept all well-pleaded factual allegations as true. Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). But it does not have to accept as true “[t]hreadbare recitals of the elements of a cause of action,” which are essentially just legal conclusions. Twombly, 550 U.S. at 555. After separating legal conclusions from well-pleaded factual allegations, the Court must determine whether those facts make it plausible – not merely possible – that the pleader is entitled to relief.

Id. BACKGROUND Plaintiff invokes the court’s federal question jurisdiction, alleging that Jimmy Wu, an employee of Defendant Wells Fargo Bank, discriminated against him when Wu made allegedly false claims to the bank’s fraud department. The following allegations are drawn from the complaint.1 On April 11, 2024, while Plaintiff was opening a new checking account at Wells Fargo Bank located at 781 Broadway in New York, New York, Wu stated that Plaintiff “refused”

1 The Court quotes from the complaint verbatim. All spelling, grammar, and punctuation are as in the complaint unless noted otherwise. to provide identification and documentation to open the account. (ECF No. 1, at 5.) Wu’s accusation “alerted the fraud department to place the account on hold,” preventing Plaintiff from making any transactions. (Id.) The bank told Plaintiff that the only way to “verify” his account was via text message to his phone. (Id.) Plaintiff alleges that his phone “was verified in person

at the branch with the banker, but the ‘back office’ team and manager stated it wasn’t, even though [Plaintiff] received a code.” (Id.) Plaintiff provided Wu with his identification and verification documents while he was at the branch office, and Wu was able to update Plaintiff’s profile since Plaintiff’s account was “locked pending verification.” (Id.) Plaintiff alleges that his account was locked for “two-three weeks” during which time he had to “go inside the branch multiple times.” (Id.) Defendant further did not honor “the $300 new checking promo once [Plaintiff] decided to open the account at a new branch after experiencing the discrimination.” (Id.) Plaintiff seeks $100,000 in damages and unspecified injunctive relief. DISCUSSION

A. Subject Matter Jurisdiction The subject matter jurisdiction of the federal district courts is limited and is set forth generally in 28 U.S.C. §§ 1331 and 1332. Under these statutes, a federal district court has jurisdiction only when a “federal question” is presented or when plaintiff and defendant are citizens of different states and the amount in controversy exceeds the sum or value of $75,000. “‘[I]t is common ground that in our federal system of limited jurisdiction any party or the court sua sponte, at any stage of the proceedings, may raise the question of whether the court has subject matter jurisdiction.’” United Food & Com. Workers Union, Loc. 919, AFL-CIO v. CenterMark Prop. Meriden Square, Inc., 30 F.3d 298, 301 (2d Cir. 1994) (quoting Manway Constr. Co., Inc. v. Hous. Auth. of the City of Hartford, 711 F.2d 501, 503 (2d Cir. 1983)); see Fed. R. Civ. P. 12(h)(3) (“If the court determines at any time that it lacks subject-matter jurisdiction, the court must dismiss the action.”); Ruhrgas AG v. Marathon Oil Co., 526 US. 574, 583 (1999) (“[S]ubject-matter delineations must be policed by the courts on their own initiative.”). 1. Federal Question Jurisdiction To invoke federal question jurisdiction, a plaintiffs claims must arise “under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. A case arises under federal law if the complaint “establishes either that federal law creates the cause of action or that the plaintiffs right to relief necessarily depends on resolution of a substantial question of federal law.” Bay Shore Union Free Sch. Dist. v. Kain, 485 F.3d 730, 734-35 (2d Cir. 2007) (quoting Empire Healthchoice Assur., Inc. v. McVeigh, 547 U.S. 677, 690 (2006)).

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Jonathan Payton v. Wells Fargo Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jonathan-payton-v-wells-fargo-bank-nysd-2025.