King Brandon Moore Bey v. American Express National Bank

CourtDistrict Court, N.D. Alabama
DecidedMarch 26, 2026
Docket5:24-cv-00927
StatusUnknown

This text of King Brandon Moore Bey v. American Express National Bank (King Brandon Moore Bey v. American Express National Bank) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
King Brandon Moore Bey v. American Express National Bank, (N.D. Ala. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION

KING BRANDON MOORE BEY,

Plaintiff,

v. Case No.: 5:24-cv-927-HDM

AMERICAN EXPRESS NATIONAL BANK,

Defendant.

MEMORANDUM OPINION Plaintiff King Brandon Moore Bey (“Bey”) has sued Defendant American Express National Bank (“American Express”), alleging common law breach of contract and violation of the Consumer Financial Protection Act. (Doc. 18). This case is before the court on the parties’ cross-motions for summary judgment. (Docs. 25, 28). After careful review of the record and applicable law, the court finds that Count One of Bey’s Third Amended Complaint, (doc. 18), is due to be DISMISSED WITHOUT PREJUDICE for lack of subject matter jurisdiction and Count Two is due to be DISMISSED WITH PREJUDICE for failure to state a claim on which relief can be granted, with the parties’ cross-motions for summary judgment DENIED AS MOOT. FACTUAL BACKGROUND On or about May 11, 2022, Bey, proceeding pro se in this matter, opened an

account with American Express and received a credit card.1 (Doc. 29-1, ¶¶ 3–4). All American Express accounts, including Bey’s, are governed by a written Cardmember Agreement (the “Agreement”) setting out the applicable terms and

conditions of the cardholder’s account. Id., ¶ 5. Bey made frequent use of his American Express-issued credit card, id., ¶ 7, and the statement period ending on November 9, 2022, showed an outstanding balance of $7,760.25, with at least $2,040.00 due on or before December 4, 2022, (Docs. 25-1 at 41; 29-1, ¶ 10; 29-6

at 5). Bey failed to timely make the required payment, and, on December 9, 2022, American Express canceled his account. (Docs. 29-1, ¶¶ 4, 9; 29-8 at 2; 33 at 3). On December 12, 2022, three days after American Express canceled his

account, Bey made a payment of $7,700, which left an outstanding balance of $60.25. (Docs. 29-1, ¶¶ 9–10; 29-7 at 4). In May of 2023, Bey paid the entire remaining balance of $60.25, leaving his account with an outstanding balance of zero dollars. (Docs. 29-1, ¶¶ 11–12; 29-7 at 11). After Bey fully paid off the

outstanding balance on his still-canceled account, no further additional charges or

1 Bey has not submitted any evidence relating to the creation and closing of his American Express account, whether in support of his own Motion for Summary Judgment, (see docs. 25; 25-1), or in opposition to American Express’s Motion, (see doc. 33). The court therefore accepts American Express’s presentation of the facts as true. interest accrued and American Express formally closed the account following the May 2023 payment. (Doc. 29-1, ¶¶ 13–14).

On March 18, 2024, with his original account still closed, Bey applied for another account and credit card, but American Express denied his application because of his credit score. (Docs. 25-1 at 34, 46; 29-1, ¶ 17; 29-9; 29-10 at 2). On

April 16, 2025, and despite this rejection and the fact that his original account had been fully paid off, closed, and canceled, Bey sent American Express a parcel via the United States Postal Service that included three documents: a power of attorney form, correspondence addressed to American Express’s Chief Financial Officer

Christopher LeCeille, and, most importantly for this case, a copy of his November 2022 billing statement with the following words handwritten on it: “Accepted for Deposit, Seven Thousand Seven Hundred Sixty Six Dollars 25/100, Pay to the Order

of Bearer” and “For: Brandon Moore/Principal; By: Moore Bey, King B/ Agent (without recourse).” (Docs. 18-1 at 51–52; 25-1 at 41–42; 29-1, ¶ 18). In the letter addressed to Mr. LeCeille, Bey instructed American Express to “apply the principal’s balance to the principal’s account” and categorized the annotated billing

statement as a “tender of payment.” (Docs. 25-1 at 30; 29-1, ¶ 18). The only reasonable reading of the contents of Bey’s parcel is that he believed that his handwritten notations on the billing statement converted it into a check that could

discharge the nonexistent balance on his closed and canceled account. On April 23, 2024, American Express sent Bey a letter affirming its decision to deny his March 2024 application for a new account and informing him that “the tender of payment

included in [his] correspondence cannot be used as an acceptable form of payment . . . ” (Docs. 25-1 at 34; 29-1, ¶ 19; 29-10). Despite this letter, on May 21, 2024, Bey resent American Express the same documents he had previously sent on April 16th.

(Doc. 29-1, ¶ 20). On June 18, 2024, Bey filed a complaint with the Consumer Financial Protection Bureau, (doc. 29-1, ¶ 21), alleging, among other things, that American Express “refus[ed] to accept valid forms of payment and adhere[] to contractual

terms” and baselessly refused to reinstate his account, (doc. 29-11 at 3–5). In response, American Express sent Bey a letter on July 3, 2024, stating it was “unable to reinstate [the] closed account or to approve [his] application . . . or to accept

unapproved payment methods.” (Docs. 25-1 at 46–47; 29-1, ¶ 22; 29-12). After receiving this letter from American Express, Bey commenced this action, (doc. 1), and has amended his complaint three times, (docs. 5; 17; 18). In the operative Third Amended Complaint, Bey asserts two causes of action against

American Express based on the above: common law breach of contract in Count One, (doc. 18, ¶¶ 11–17), and violation of the Consumer Financial Protection Act in Count Two, id., ¶¶ 18–23, for which he seeks compensatory damages, as well as

injunctive and declaratory relief. (Doc. 18 at 4–6). Bey alleges that American Express’s actions caused him to incur “penalties, late fees, and interest inflating the balance [of his account] from $7,000 to over $210,000.” Id., ¶ 10. Upon Bey’s

Motion, (doc. 2), the court has allowed him to prosecute this case in forma pauperis, (doc. 6), and, as a pro se plaintiff, the court will afford Bey more leeway, Dean v. Barber, 951 F.2d 1210, 1213 (11th Cir. 1992) (citations omitted).

ANALYSIS The court finds that Count One of Bey’s Third Amended Complaint is due to be DISMISSED WITHOUT PREJUDICE for lack of subject matter jurisdiction

and Count Two is due to be DISMISSED WITH PREJUDICE for failure to state a claim on which relief can be granted. As explained below, the court finds it necessary to begin with Count Two and then examine how its dismissal affects the

court’s subject matter jurisdiction over Count One. I. Count Two: No Private Right of Action Under the Consumer Financial Protection Act

In Count Two of the Third Amended Complaint, Bey alleges that American Express violated the Consumer Financial Protection Act, 12 U.S.C. §§ 5301–5641 (the “Act”) by refusing to accept his “payments” in April and May of 2024. (Doc. 18, ¶¶ 18–23). The fatal flaw underlying Count Two is that, despite Bey’s allegations, he can never recover under the Act because it does not provide a private right of action for individuals. A plaintiff may only assert a claim under a federal statute if Congress has expressly or impliedly permitted such a private right of action. See, e.g., Alexander

v. Sandoval, 532 U.S. 275, 286 (2001). This court has summarized the necessity of a private right of action thus: A private right of action is “an individual’s right to sue in a personal capacity to enforce a legal claim.” Right of Action, BLACK’S LAW DICTIONARY (10th ed. 2014). Not every federal statute provides a private right of action.

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King Brandon Moore Bey v. American Express National Bank, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-brandon-moore-bey-v-american-express-national-bank-alnd-2026.