Lewis v. Old Navy

District Court, S.D. New York·Decided October 25, 2024·No. 7:21-cv-09131·Unknown

Opinion

DIOUUNILEIN 1 | ELECTRONICALLY FILED DOC #: UNITED STATES DISTRICT COURT DATE FILED: 10/25/2024 SOUTHERN DISTRICT OF NEW YORK ——

REGINA LEWIS,

-against- 21-cv-9131 (NSR) OPINION & ORDER OLD NAVY et al. Defendants. Nelson S. Roman, United States District Court Judge: Plaintiff Regina Lewis (“Plaintiff”), proceeding pro se, brings this action against Defendant Synchrony Bank and Defendant Old Navy (collectively, “Defendants”), asserting violations of the Fair Credit Reporting Act (“FCRA”). (Second Amended Complaint (“SAC”), ECF No. 33.) Presently before the Court is Defendants’ motion to dismiss the SAC pursuant to Federal Rules of Civil Procedure 12(b). (‘Defendants’ Motion”, ECF No. 40.) For the following reasons, Defendants’ Motion is GRANTED. BACKGROUND The allegations in the SAC are deemed true for the purpose of resolving Defendants’ Motion. Plaintiff held multiple credit cards issued by Synchrony, including a La-Z-Boy account, a Mattress Firm account, an Old Navy account, and a Pandora account. (See SAC Exhibit A.) She alleges that she made a payment to her Old Navy account of $159.58 on August 2, 2021, but that the payment was misapplied. (/d. at 1.) As a result of the misapplication, Synchrony allegedly agreed to refund interest and late fees and correct any derogatory credit reporting. (/d.) Plaintiff further alleges that a second payment of $100 on August 2, 2021 was misposted to her Pandora

account, and that her Pandora account was later closed with a $0 balance. (Id. at 2.) She contends that Synchrony never refunded or reapplied either of the payments, and that she has thus suffered a loss in the amount of $259.58. (Id.) PROCEDURAL HISTORY On November 3, 2021, Plaintiff commenced this action against the Defendants.

(Complaint, ECF No. 2.) On February 2, 2022, the Court dismissed the Complaint sua sponte for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii). (ECF No. 4.) On February 17, 2022, Plaintiff filed an Amended Complaint (ECF No. 6), which the Court construed as a motion for reconsideration, (ECF No. 7). The Court granted Plaintiff’s motion for reconsideration and vacated the dismissal of the Complaint. (Id.) On March 22, 2023, the Defendants filed a motion to dismiss the Amended Complaint (ECF No. 27), which the Court granted on January 9, 2024 (ECF No. 32). On February 6, 2024, Plaintiff filed the SAC. (ECF No. 33.) On July 15, 2024, Defendants filed a motion to dismiss the SAC (ECF No. 40) and a memorandum of law in support (id). On August 26, 2024, Plaintiff

submitted a response in opposition to Defendants’ motion to dismiss. (ECF No. 41.) LEGAL STANDARD A claim is subject to dismissal under Rule 12(b)(1) if the Court lacks subject matter jurisdiction to adjudicate it pursuant to statute or constitutional authority. See Fed. R. Civ. P. 12(b)(1); Makarova v. United States, 201 F.3d 110, 113 (2d Cir. 2000). Where a party lacks standing to bring a claim, the Court lacks subject matter jurisdiction over such claim. See SM Kids, LLC v. Google LLC, 963 F.3d 206, 210 (2d Cir. 2020). To have standing, a plaintiff must prove: (1) he or she has suffered a “concrete and particularized injury”; (2) the injury “is fairly traceable to the challenged conduct”; and (3) the injury “is likely to be redressed by a favorable judicial decision.” Hollingsworth v. Perry, 570 U.S. 693, 704 (2013) (citing Lujan v. Defs. of Wildlife, 504 U.S. 555, 560–61 (1992)). In resolving a motion to dismiss for lack of subject matter jurisdiction, the Court must accept as true all material factual allegations in the complaint, but will not draw inferences favorable to the party asserting jurisdiction. Shipping Fin. Servs. Corp. v. Drakos, 140 F.3d 129,

131 (2d Cir. 1998). The plaintiff bears the burden of proving by a preponderance of the evidence that the Court has subject matter jurisdiction of the claim asserted. Robinson v. Overseas Military Sales Corp., 21 F.3d 502, 507 (2d Cir. 1994). DISCUSSION Plaintiff’s SAC purports to assert claims sounding in failure to report accurate information and failing to correct inaccurate information under the FCRA. The FCRA, 15 U.S.C. § 1681 et seq., regulates credit reporting agencies and mandates them to adopt reasonable procedures to ensure the confidentiality, accuracy, relevancy, and proper utilization of consumers’ information. See 15 U.S.C. § 1681(b). The FCRA imposes several responsibilities

upon credit reporting agencies, including to refrain from knowingly reporting inaccurate information under 15 U.S.C. § 1681s–2(a)(1) and to correct any information they later discover to be inaccurate under 15 U.S.C. § 1681s–2(a)(2). Longman v. Wachovia Bank, N.A., 702 F.3d 148, 150 (2d Cir. 2012). A creditor’s failure to investigate and correct the disputed information pursuant to 15 U.S.C. § 1681s-2(b) creates a private cause of action. Holland v. Chase Bank USA, N.A., 475 F. Supp. 3d 272, 276 (S.D.N.Y. 2020) (citing Matheson v. Ocwen Fed. Bank FSB, 2008 WL 11413560, at *7 (E.D.N.Y. June 18, 2008)). The Supreme Court has made clear that “a bare procedural violation” of the FCRA “divorced from any concrete harm” fails to satisfy the injury-in-fact requirement of Article III. Spokeo, Inc. v. Robins, 578 U.S. 330, 341 (2016), as revised (May 24, 2016). Rather, to establish Article III standing, a plaintiff must show that he has suffered concrete harm. TransUnion LLC v. Ramirez, 141 S. Ct. 2190, 2200 (2021). Such harm can be monetary or physical, Spokeo, 578 U.S. at 340, and need not always be tangible in nature, TransUnion LLC, 141 S. Ct. at 2208. However, “mere risk of future harm, standing alone, cannot qualify as a concrete harm—at least

unless the exposure to the risk of future harm itself causes a separate concrete harm.” Scott v. Affirm, Inc., No. 22CV04432ARRJMW, 2022 WL 18859070, at *2 (E.D.N.Y. Sept. 30, 2022) (citation omitted) (emphasis in original); see, e.g. Gross v. TransUnion, LLC, 607 F. Supp. 3d 269, 273 (E.D.N.Y. 2022) (finding TransUnion's alleged credit error did not cause plaintiff “concrete and particularized harm” because the alleged harms were “not expenses, costs, any specific lost credit opportunity, or specific emotional injuries”). If a plaintiff fails to satisfy the injury-in-fact requirement of Article III, a federal court lacks subject matter jurisdiction over plaintiff's FCRA claims. See Zlotnick v. Equifax Info. Servs., LLC, 583 F.Supp.3d 387, 392 (E.D.N.Y. 2022).

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

Lewis v. Old Navy, (S.D.N.Y. 2024).

Lewis v. Old Navy (Lewis v. Old Navy) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Natalia Makarova v. United States
201 F.3d 110 (Second Circuit, 2000)
Longman v. Wachovia Bank, N.A.
702 F.3d 148 (Second Circuit, 2012)
Hollingsworth v. Perry
133 S. Ct. 2652 (Supreme Court, 2013)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
SM Kids, LLC v. Google LLC
963 F.3d 206 (Second Circuit, 2020)
TransUnion LLC v. Ramirez
594 U.S. 413 (Supreme Court, 2021)
Robinson v. Overseas Military Sales Corp.
21 F.3d 502 (Second Circuit, 1994)
Katz v. Donna Karan Co.
872 F.3d 114 (Second Circuit, 2017)