Nordheim v. JP Morgan Chase Bank N.A.

CourtDistrict Court, N.D. California
DecidedJuly 11, 2025
Docket3:25-cv-04781
StatusUnknown

This text of Nordheim v. JP Morgan Chase Bank N.A. (Nordheim v. JP Morgan Chase Bank N.A.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nordheim v. JP Morgan Chase Bank N.A., (N.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 ODIN NORDHEIM, Case No. 25-cv-04781-LB

12 Plaintiff, SCREENING ORDER 13 v. Re: ECF No. 1 14 JP MORGAN CHASE BANK N.A., 15 Defendant. 16 17 INTRODUCTION AND STATEMENT 18 Plaintiff Odin Nordheim, who is proceeding pro se and in forma pauperis, sued defendant JP 19 Morgan Chase Bank, alleging discrimination based on his disability and asylum status and 20 financial-disclosure violations, with resulting harm to his emotional wellbeing and his credit 21 rating, generally because Chase closed his bank account and refused to reopen it. When he tried to 22 deposit and withdraw funds from his Chase account, a Chase teller humiliated him by questioning 23 him publicly. A security guard approached him aggressively, which made him feel unsafe. Chase 24 then closed his account without notice, issued him a check for his account balance of $77.56, and 25 did not respond to his requests for an apology or explanation.1 The plaintiff can no longer access 26 27 1 1 banking services because Chase will not allow him to open a new account, and other banks have 2 rejected his attempts to open accounts, possibly because Chase shared his information with them.2 3 The plaintiff struggles to access services and participate in society, and he is vulnerable to further 4 hardship and risk based on his inability to access the financial system.3 5 The plaintiff identifies two claims against Chase. 6 The first claim lists “42 U.S.C. § 1981; ADA (42 U.S.C. §§ 12101 et seq.), FCRA (15 U.S.C. 7 § 1681 et seq.), and GLBA (15 U.S.C. § 6801 et seq.),” and explains that (1) 42 U.S.C. § 1981 8 gives the plaintiff the same rights to contract and receive services as any other citizen, (2) the 9 ADA requires access to services for disabled people for public services, (3) the Fair Credit 10 Reporting Act (FCRA) and Graham-Leach-Bliley Act (GLBA) protect against wrongful sharing of 11 his financial information, (4) California’s Unfair Competition Law (UCL) and Unruh Act ban 12 discrimination by businesses, and (5) the Fourteenth Amendment protects equal access and due 13 process under law.4 14 The second claim lists “42 U.S.C. § 1981; ADA (42 U.S.C. §§ 12101 et seq.); FCRA (15 U.S.C. 15 § 1681 et seq.), GLBA (15 U.S.C. § 6801 et seq.); UCL (Cal. Bus. & Prof. Code § 17200); Unruh 16 Act (Cal. Civ. Code § 51); and 14th Amend[ment]” and explains that (1) the laws protect his rights 17 to access banking, receive equal treatment, and keep his financial data safe, (2) the teller questioned 18 him publicly, causing humiliation, (3) the security guard made him feel unsafe, and (4) Chase 19 closed his account, barred new accounts, and may have reported his negative record to other banks, 20 causing them to reject his attempts to open accounts. As a result, his financial reputation and 21 creditworthiness suffered, he is anxious, overwhelmed, distressed, and humiliated, and he believes 22 the treatment — which effectively excluded him from the financial system — was due to his 23 disability and asylum status.5 24 The plaintiff asks for $10 million in damages, litigation costs, an apology, and an injunction 25 26 2 Id. at 4, 6. 3 Id. at 7. 27 4 Id. at 5. 1 against further discrimination or blacklisting, among other requests.6 2 Before directing the United States Marshal to serve the defendant with the complaint, the court 3 must screen it for minimal legal viability. 28 U.S.C. § 1915(e)(2)(B). The court issues this screening 4 order to give the plaintiff notice of the deficiencies in his lawsuit and an opportunity to cure them 5 by filing a supplement to his existing filing by July 28, 2025, or the court will recommend 6 dismissing the case. The deficiency generally is that the plaintiff does not allege facts supporting 7 legally cognizable claims. 8 STANDARD OF REVIEW 9 1. Federal Jurisdiction 10 Federal courts are courts of limited jurisdiction. Owen Equip. & Erection Co. v. Kroger, 437 U.S. 11 365, 374 (1978). A plaintiff must show either federal-question jurisdiction or diversity jurisdiction. 12 Caterpillar Inc. v. Williams, 482 U.S. 386, 392 (1987). Federal-question jurisdiction exists if a case 13 arises under the Constitution, laws, or treaties of the United States. 28 U.S.C. § 1331. Diversity 14 jurisdiction exists if the opposing parties are citizens of different states and the amount in controversy 15 exceeds $75,000. Id. § 1332(a). 16 17 2. IFP Review 18 Before a court can direct the U.S. Marshal to serve — under Fed. R. Civ. P. 4(c)(2) — the 19 complaint of a person proceeding in forma pauperis under 28 U.S.C. § 1915(a), the court must 20 determine whether the complaint is frivolous, malicious, fails to state a claim upon which relief may 21 be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 22 1915(e)(2)(B); Calhoun v. Stahl, 254 F.3d 845, 845 (9th Cir. 2001); Lopez v. Smith, 203 F.3d 1122, 23 1126–27 (9th Cir. 2000) (en banc), overruled in part on other grounds by Peralta v. Dillard, 744 24 F.3d 1076 (9th Cir. 2014) (en banc). “The language of § 1915(e)(2)(B)(ii) parallels the language of 25 Federal Rule of Civil Procedure 12(b)(6).” Barren v. Harrington, 152 F.3d 1193, 1194 (9th Cir. 26 1998). The in forma pauperis statute “is designed largely to discourage the filing of, and waste of 27 1 judicial and private resources upon, baseless lawsuits that paying litigants generally do not initiate 2 because of the costs of bringing suit.” Neitzke v. Williams, 490 U.S. 319, 327 (1989). 3 “Frivolousness” under § 1915(e) and failure to state a claim under Rule 12(b)(6) are distinct 4 concepts. 5 “A complaint . . . is frivolous where it lacks an arguable basis either in law or in fact.” Denton 6 v. Hernandez, 504 U.S. 25, 31 (1992).

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