Jones-Eiland v. Chime Financial Inc.

CourtDistrict Court, D. Delaware
DecidedJuly 5, 2022
Docket1:22-cv-00111
StatusUnknown

This text of Jones-Eiland v. Chime Financial Inc. (Jones-Eiland v. Chime Financial Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones-Eiland v. Chime Financial Inc., (D. Del. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE TYRRELL L. JONES-EILAND, Plaintiff, Vv. : Civil Action No. 22-111-CFC CHIME FINANCIAL, INC., et al., Defendants.

Tyrrell L. Jones-Eiland, New York, New York. Pro Se Plaintiff.

MEMORANDUM OPINION

July 5, 2022 Wilmington, Delaware

CONNOLLY, Chief Judge: Plaintiff Tyrrell L. Jones-Eiland appears pro se and has been granted leave to proceed in forma pauperis. (D.|. 6) He commenced this action on January 27, 2022, pursuant to 42 U.S.C. § 1983, 15 U.S.C. § 1687a(f), and 15 U.S.C. § 1681. (D.I. 2) The Court proceeds to screen the Complaint pursuant to 28 U.S.C. § 1915(e)(2)(B). I. BACKGROUND The following facts are taken from the Complaint and assumed to be true for screening purposes. See Umland v. PLANCO Fin. Servs., Inc., 542 F.3d 59, 64 (3d Cir. 2008). Plaintiff alleges that Defendant State of Nevada prolonged disbursing PUA (i.e., Pandemic Unemployment Assistance) payments for over six months, sent a lump sum payment to Plaintiff's Chime checking account, and that Plaintiff then sent a portion of the monies to his secured credit card account. (D.I. 2 at 4) Within days of payment to Defendant Chime Financial Inc, through Defendant Stride Bank N.A., the systems of Defendant The Bancorp determined that Plaintiffs disbursement from the State of Nevada was fraudulent, cancelled Plaintiff's cards, held the money, and blocked all communications with Plaintiff. (/d.) Plaintiff alleges that his accounts were closed with no warning or legitimate notice. (/d.) In addition, Chime deferred all questions to the State of Nevada, which waited over a year before it sent Plaintiff a partial tracking number and refused to re-disburse Plaintiff's funds to a new banking account. (/d.) Plaintiff alleges that the State of Nevada holds Chime, Stride, and Bancorp responsible, while the three entities hold the State of Nevada responsible and indicate that it has the money. (/d.)

Plaintiff, who has been dealing with this matter since June 2020, seeks compensatory damages. (/d.) Il. LEGAL STANDARDS A federal court may properly dismiss an action sua sponte under the screening provisions of 28 U.S.C. § 1915(e)(2)(B) if “the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief.” Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013). The Court must accept all factual allegations in a complaint as true and take them in the light most favorable to a pro se plaintiff. Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008); Erickson v. Pardus, 551 U.S. 89, 93 (2007). Because Plaintiff proceeds pro se, his pleading is liberally construed and his Complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. at 94 (citations omitted). A complaint is not automatically frivolous because it fails to state a claim. See Dooley v. Wetzel, 957 F.3d. 366, 374 (3d Cir. 2020) (quoting Neitzke v. Williams, 490 U.S. 319, 331 (1989)); see also Grayson v. Mayview State Hosp., 293 F.3d 103, 112 (3d Cir. 2002). “Rather, a claim is frivolous only where it depends ‘on an “indisputably meritless legal theory” or a “clearly baseless” or “fantastic or delusional” factual scenario.” Dooley v. Wetzel, 957 F.3d at 374 (quoting Mitchell v. Horn, 318 F.3d 523, 530 (2003) and Neitzke, 490 U.S. at 327-28). The legal standard for dismissing a complaint for failure to state a claim pursuant to § 1915(e)(2)(B) is identical to the legal standard used when ruling on Rule 12(b)(6) motions. Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999). However, before

dismissing a complaint or claims for failure to state a claim upon which relief can be granted pursuant to the screening provisions of 28 U.S.C. § 1915(e)(2)(B), the Court must grant Plaintiff leave to amend the complaint unless amendment would be inequitable or futile. See Grayson v. Mayview State Hosp., 293 F.3d at 114. A complaint may be dismissed only if, accepting the well-pleaded allegations in the complaint as true and viewing them in the light most favorable to the plaintiff, a court concludes that those allegations “could not raise a claim of entitlement to relief.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 558 (2007). Though “detailed factual allegations” are not required, a complaint must do more than simply provide “labels and conclusions” or “a formulaic recitation of the elements of a cause of action.” Davis v. Abington Mem’! Hosp., 765 F.3d 236, 241 (3d Cir. 2014) (internal quotation marks omitted). In addition, a complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. See Williams v. BASF Catalysts LLC, 765 F.3d 306, 315 (3d Cir. 2014) (citing Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) and Twombly, 550 U.S. at 570). Finally, a plaintiff must plead facts sufficient to show that a claim has substantive plausibility. See Johnson v. City of Shelby, 574 U.S. 10 (2014). A complaint may not be dismissed for imperfect statements of the legal theory supporting the claim asserted. See id. at 10. A court reviewing the sufficiency of a complaint must take three steps: (1) take note of the elements the plaintiff must plead to state a claim; (2) identify allegations that,

. because they are no more than conclusions, are not entitled to the assumption of truth; and (3) assume the veracity of any well-pleaded factual allegations and then determine whether those allegations plausibly give a an entitlement to relief. Connelly v.

Lane Const. Corp., 809 F.3d 780, 787 (3d Cir. 2016) (internal citations and quotations omitted). Elements are sufficiently alleged when the facts in the complaint “show” that the plaintiff is entitled to relief. Iqbal, 556 U.S. at 679 (quoting Fed. R. Civ. P. 8(a)(2)).

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Related

Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Safeco Insurance Co. of America v. Burr
551 U.S. 47 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Simmsparris v. Countrywide Financial Corp.
652 F.3d 355 (Third Circuit, 2011)
Dennis O'COnnOr v. State of Nevada
686 F.2d 749 (Ninth Circuit, 1982)
Mark Mitchell v. Martin F. Horn
318 F.3d 523 (Third Circuit, 2003)
Evancho v. Fisher
423 F.3d 347 (Third Circuit, 2005)
Dawn Ball v. Famiglio
726 F.3d 448 (Third Circuit, 2013)
Phillips v. County of Allegheny
515 F.3d 224 (Third Circuit, 2008)
Umland v. PLANCO Financial Services, Inc.
542 F.3d 59 (Third Circuit, 2008)
Edward Seamans v. Temple University
744 F.3d 853 (Third Circuit, 2014)
Collette Davis v. Abington Mem Hosp
765 F.3d 236 (Third Circuit, 2014)
Kimberlee Williams v. BASF Catalysts LLC
765 F.3d 306 (Third Circuit, 2014)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Donald Parkell v. Carl Danberg
833 F.3d 313 (Third Circuit, 2016)
Casey Dooley v. John Wetzel
957 F.3d 366 (Third Circuit, 2020)

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Bluebook (online)
Jones-Eiland v. Chime Financial Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-eiland-v-chime-financial-inc-ded-2022.