Maxwell v. Synchrony Financial

CourtDistrict Court, N.D. Ohio
DecidedJuly 26, 2024
Docket1:24-cv-00561
StatusUnknown

This text of Maxwell v. Synchrony Financial (Maxwell v. Synchrony Financial) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Maxwell v. Synchrony Financial, (N.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

MICHELLE MAXWELL, ) CASE NO. 1:24-CV-561 ) Plaintiff, ) JUDGE BRIDGET MEEHAN BRENNAN ) v. ) ) SYNCHRONY FINANCIAL, ) MEMORANDUM OPINION ) AND ORDER Defendant. )

On March 26, 2024, pro se Plaintiff Michelle Maxwell filed this action against Synchrony Financial. (Doc. No. 1.) Plaintiff contends that Synchrony Financial’s refusal to accept payment for her credit card is a breach of contract and a violation of the Bill of Exchange Act, the Federal Reserve Act, and 12 U.S.C. § 1431. (Doc. No. 1-1 at 6.)1 Plaintiff also filed a motion to Proceed In Forma Pauperis (Doc. No. 2), which is GRANTED. For the reasons below, Plaintiff’s complaint is DISMISSED. I. BACKGROUND

Plaintiff alleges that on June 27, 2022, she applied for a credit card for Dick’s Sporting Goods. (Doc. No. 1-1 at 6.) This credit card is provided and serviced by Synchrony Financial. (Id.) Plaintiff made purchases totaling $2,663.78 using her credit card. (See Doc. No. 1-3 at 9.) Plaintiff attached a billing statement from Synchrony Financial to her complaint that showed she had a minimum payment of $318.00 due on September 3, 2023. (Doc. No. 1-4 at 11.) This statement also indicated that Plaintiff had a past due balance of $195.00, had exceeded her purchase limit by $237.18, and had a new balance of $2,237.18. (Id.) It appears that instead of submitting payment by check, money order, over the phone, or online, Plaintiff wrote on the

1 For ease and consistency, record citations are to the electronically stamped CM/ECF document and PageID# rather than any internal pagination. billing statement “accepted for deposit,” “two thousand two hundred thirty seven dollars and eighteen cents,” “2,237 18/100,” and “pay to the bearer.” (Id.) Plaintiff then sent the billing statement with her markings to Synchrony Financial as payment. (Id.) Plaintiff contends that in doing so, she “tendered a negotiable instrument in accordance with the bill of exchange act[,] and Federal Reserve act.” (Doc. No. 1-1 at 6.)

Plaintiff received another billing statement from Synchrony Financial indicating that a payment of $846.00 was due on January 3, 2024. (Doc. No. 1-3 at 10.) That statement indicated that Plaintiff had a past due balance of $707.00, had exceeded her purchase limit by $663.78, and had a new balance of $2,663.78. (Id.) As with her previous billing statement, Plaintiff wrote “accepted for deposit,” “two thousand six hundred sixty three dollars and seventy eight cents,” “2,663 18/100,” and “pay to the order of bear[er]” on the billing statement and returned it to Synchrony Financial as payment. (Id.) Plaintiff contends that this document also constituted a “negotiable instrument in accordance with the bill of exchange act[,] and Federal Reserve act.” (Doc. No. 1-1 at 6.)

In June 2023, Plaintiff mailed a set of instructions to Synchrony Financial and its CFO, Brian J. Wenzel, requesting that he “apply the principles balance to [Plaintiff’s account], for set off each and every billing cycle” within five business days. (Doc. No. 1-5 at 13.) Later in June 2023, Plaintiff sent additional correspondence to Synchrony Financial inquiring about her account and threatening to “file a complaint for assessment with the OCC” for “security fraud and breach of contract.” (Doc. No. 1-6 at 14.) In July 2023, Synchrony Financial sent Plaintiff a letter regarding her account. (Doc. No. 1-8 at 16.) Synchrony Financial stated that it did not recognize Plaintiff’s responses to the

2 billing statements as a method of payment. (See id.) Synchrony Financial stated that Plaintiff’s account “is governed by the Synchrony Financial credit card agreement and we reject any attempt on your part to modify the terms of the agreement of our relationship.” (Id.) In September 2023, Synchrony Financial sent another letter explaining that it did not accept Plaintiff’s additional correspondence as payment. (Doc. No. 1-9 at 17.)

Also in September 2023, the Office of the Comptroller of the Currency (“OCC”) responded to correspondence from Plaintiff and conducted a second review of her complaint. (Doc. No. 1-7 at 15.) The OCC referred Plaintiff to the Consumer Financial Protection Bureau, which “has jurisdiction on issues covered under federal consumer protection laws and financial institutions with assets of $10 billion and above.” (Id.) On March 26, 2024, Plaintiff commenced this action, claiming that Synchrony Financial breached its contract and violated the Bill of Exchange Act, the Federal Reserve Act, and laws governing banking institutions. (Doc. No. 1-1 at 6.) Plaintiff’s complaint requests that Synchrony Financial reopen her account, remove any and all derogatory marks from credit

reporting agencies, pay $14,000 in damages, and pay $250,000 for “special performance of the contract.” (Id.) II. LEGAL STANDARD

Although pro se pleadings are liberally construed, Boag v. MacDougall, 454 U.S. 364, 365 (1982) (per curiam); Haines v. Kerner, 404 U.S. 519, 520 (1972), the Court is required to dismiss an in forma pauperis action under 28 U.S.C. §1915(e) if it fails to state a claim upon which relief can be granted, or if it lacks an arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319 (1989); Lawler v. Marshall, 898 F.2d 1196 (6th Cir. 1990); Sistrunk v. City of 3 Strongsville, 99 F.3d 194, 197 (6th Cir. 1996). A claim lacks an arguable basis in law or fact when it is premised on an indisputably meritless legal theory or when the factual contentions are clearly baseless. Neitzke, 490 U.S. at 327. A cause of action fails to state a claim upon which relief may be granted when it lacks “plausibility in the Complaint.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564 (2007). A

pleading must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 677-78 (2009). The factual allegations in the pleading must be sufficient to raise the right to relief above the speculative level on the assumption that all the allegations in the Complaint are true. Bell Atl. Corp., 550 U.S. at 555. A plaintiff is not required to include detailed factual allegations, but must provide more than “an unadorned, the-Defendant-unlawfully-harmed-me accusation.” Iqbal, 556 U.S. at 678. A pleading that offers legal conclusions or a simple recitation of the elements of a cause of action will not meet this pleading standard. Id. In reviewing a complaint, the Court must construe the pleading in the light most favorable to the plaintiff. Bibbo v. Dean Witter Reynolds, Inc., 151

F.3d 559, 561 (6th Cir.1998). III. ANALYSIS

Federal courts are courts of limited jurisdiction; without jurisdiction conferred by statute, they lack the power to adjudicate claims. Caterpillar Inc. v. Williams, 482 U.S. 386, 392 (1987); Ohio ex rel. Skaggs v. Brunner, 549 F.3d 468, 474 (6th Cir.

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Related

Bell v. Hood
327 U.S. 678 (Supreme Court, 1946)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Boag v. MacDougall
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Caterpillar Inc. v. Williams
482 U.S. 386 (Supreme Court, 1987)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Arbaugh v. Y & H Corp.
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Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ohio Ex Rel. Skaggs v. Brunner
549 F.3d 468 (Sixth Circuit, 2008)
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Maxwell v. Synchrony Financial, Counsel Stack Legal Research, https://law.counselstack.com/opinion/maxwell-v-synchrony-financial-ohnd-2024.