Paul v. American Express

CourtDistrict Court, S.D. New York
DecidedJanuary 3, 2023
Docket1:22-cv-05728
StatusUnknown

This text of Paul v. American Express (Paul v. American Express) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Paul v. American Express, (S.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK SELWYN PAUL, Plaintiff, 22-CV-5728 (LTS) -against- ORDER TO AMEND AMERICAN EXPRESS, Defendant. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff Selwyn Paul, of Mount Vernon, New York, filed this pro se action. He sues American Express, alleging that American Express violated his rights. By order dated October 25, 2022, the Court granted Plaintiff’s request to proceed without prepayment of fees, that is, in forma pauperis (IFP). For the reasons set forth below, the Court grants Plaintiff leave to file an amended complaint within 60 days of the date of this order. STANDARD OF REVIEW The Court must dismiss an IFP complaint, or any portion of the complaint, that is frivolous or malicious, fails to state a claim on which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B); see Livingston v. Adirondack Beverage Co., 141 F.3d 434, 437 (2d Cir. 1998). The Court must also dismiss a complaint when the Court lacks subject matter jurisdiction. See Fed. R. Civ. P. 12(h)(3). While the law mandates dismissal on any of these grounds, the Court is obliged to construe pro se pleadings liberally, Harris v. Mills, 572 F.3d 66, 72 (2d Cir. 2009), and interpret them to raise the “strongest [claims] that they suggest,” Triestman v. Fed. Bureau of Prisons, 470 F.3d 471, 474 (2d Cir. 2006) (internal quotation marks and citations omitted) (emphasis in original). But the “special solicitude” in pro se cases, id. at 475 (citation omitted), has its limits – to state a claim, pro se pleadings still must comply with Rule 8 of the Federal Rules of Civil Procedure, which requires a complaint to make a short and plain statement showing that the pleader is entitled to relief.

The Supreme Court has held that, under Rule 8, a complaint must include enough facts to state a claim for relief “that is plausible on its face.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007). A claim is facially plausible if the plaintiff pleads enough factual detail to allow the Court to draw the inference that the defendant is liable for the alleged misconduct. In reviewing the complaint, the Court must accept all well-pleaded factual allegations as true. Ashcroft v. Iqbal, 556 U.S. 662, 678-79 (2009). But it does not have to accept as true “[t]hreadbare recitals of the elements of a cause of action,” which are essentially just legal conclusions. Twombly, 550 U.S. at 555. After separating legal conclusions from well-pleaded factual allegations, the Court must determine whether those facts make it plausible – not merely possible – that the pleader is entitled to relief. Id.

BACKGROUND Plaintiff brings this action using the Court’s general complaint form, and he invokes the Court’s federal question jurisdiction. In the section that asks Plaintiff which of his federal constitutional or federal statutory rights have been violated, Plaintiff writes, “15 USC 1691(a)(3), 15 USC 1681q, 15 USC 1602(p), 15 USC 1611(1), 15 USC 1602(f), and 15 USC 1681(a)(4).” (ECF No. 2 at 2.) In his statement of claim, Plaintiff alleges the following: American Express is in violation of 15 USC 1691(a)(3) for discrimination, 15 USC 1681q for obtaining information under false pretenses in order to mislead and deceive me, 15 USC 1602(p) for unauthorized us, 15 USC 1611(1) for giving me false and inaccurate information willingly and knowingly, 15 USC 1602(f) for denying me my righ[t] to credit that I was granted from birth, and 15 USC 1681(a)(4) for not respecting my right to privacy. (Id. at 5.) By way of relief, Plaintiff states that he wishes “to be compensated $6,000 dollars for my consumer rights being violated and I want my American Express Gold Card as well.” (Id. at 6.) DISCUSSION The Court construes Plaintiff’s allegations as asserting claims under the Fair Credit

Reporting Act (“FCRA”), 15 U.S.C. § 1681 et seq. and the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. § 1692, based upon Plaintiff’s citing federal statutes that govern accessing credit information and his allegation that American Express discriminated against him. A. FCRA Congress enacted the FCRA to ensure that “consumer reporting agencies adopt reasonable procedures for meeting the needs of commerce for consumer credit, personnel, insurance, and other information in a manner which is fair and equitable to the consumer, with regard to the confidentiality, accuracy, relevancy, and proper utilization of such information.” 15 U.S.C. § 1681(b). The FCRA regulates the activities of consumer reporting agencies and the use and dissemination of consumer credit information. See 15 U.S.C. § 1681 et seq. The FCRA

places obligations on three types of entities involved in consumer credit: consumer reporting agencies, users of consumer reports, and furnishers of information to consumer reporting agencies. See Burns v. Bank of America, No. 03 Civ. 1685 (RMB) (JCF), 2003 WL 22990065, at *2 (S.D.N.Y. Dec. 18, 2003); Redman v. Winston & Winston P.C., No. 01 Civ. 11475 (DLC), 2002 WL 31106934, at * 3 (S.D.N.Y. Sept. 20, 2002). Reporting Inaccurate Information The FCRA imposes certain duties on entities furnishing information to consumer reporting agencies. 15 U.S.C. § 1681s-2.1 Subsection 1681s-2 (a) states that persons “shall not furnish any information relating to a consumer to any consumer reporting agency if the person knows or has reasonable cause to believe that the information is inaccurate.” 15 U.S.C. § 1681s– 2(a)(1)(A). But “there is no private cause of action for violations of § 1681s–2(a).” Longman v.

Wachovia Bank, N.A., 702 F.3d 148, 151 (2d Cir. 2012). This is because subsection (a) of the FCRA “shall be enforced exclusively . . . by the Federal agencies and officials and the State officials identified in section 1681s of this title.” 15 U.S.C. § 1681s–2(d); Comunale v. Home Depot, U.S.A., Inc., 328 F. Supp. 3d 70, 79 (W.D.N.Y. 2018) (“There is no private cause of action under Section 1681s-2(a), for the FCRA limits the enforcement of this subsection to government agencies and officials.”).

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Bluebook (online)
Paul v. American Express, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-v-american-express-nysd-2023.