Philip Markowitz v. JPMorgan Chase Bank, N.A.

CourtDistrict Court, C.D. California
DecidedDecember 23, 2024
Docket2:23-cv-06528
StatusUnknown

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

Bluebook
Philip Markowitz v. JPMorgan Chase Bank, N.A., (C.D. Cal. 2024).

Opinion

O 1

2 3 4 5 6 7

8 United States District Court 9 Central District of California

11 PHILIP MARKOWITZ, Case № 2:23-cv-06528-ODW (MRWx)

12 Plaintiff, ORDER GRANTING IN PART AND

13 v. DENYING IN PART DEFENDANT’S MOTION FOR SUMMARY 14 JPMORGAN CHASE BANK, N.A. et al., JUDGMENT [32]

15 Defendants.

16 17 I. INTRODUCTION 18 Plaintiff Philip Markowitz brings this action against Defendant JPMorgan 19 Chase Bank, N.A. (“Chase”) for alleged improper retention of funds in Markowitz’s 20 bank accounts. (Notice of Removal (“NOR”) Ex. 1 (“Compl.”), ECF Nos. 1, 1-1.) 21 Chase now moves for summary judgment. (Mot. Summ. J. (“Motion” or “Mot.”), 22 ECF No. 32.) For the reasons discussed below, the Court GRANTS IN PART AND 23 DENIES IN PART Chase’s Motion.1 24 25 26 27

28 1 Having carefully considered the papers filed in connection with the Motion, the Court deemed the matter appropriate for decision without oral argument. Fed. R. Civ. P. 78; C.D. Cal. L.R. 7-15. 1 II. BACKGROUND 2 The Court takes the following undisputed facts from Chase’s Statement of 3 Uncontroverted Facts (“SUF”), (ECF No. 32-1), and Markowitz’s Statement of 4 Genuine Disputes of Material Fact (“SGDF”), (ECF No. 34-1). 5 On May 2, 2017, Markowitz signed a “Personal Signature Card” for a Chase 6 Better Banking Checking account ending in 7449 (the “Account”), agreeing to be 7 bound by the Deposit Account Agreement, effective March 2017 (“2017 DAA”) and 8 “as amended from time to time.” (SUF ¶¶ 1, 3–4.) The Deposit Account Agreement, 9 effective March 2023 (“2023 DAA”), governed the Account as of March 19, 2023. 10 (Id. ¶ 6.) The 2017 DAA and 2023 DAA (the “DAAs”) provide that Chase or 11 Markowitz may close the Account “at any time for any reason or no reason without 12 prior notice.” (Id. ¶ 12.) The DAAs further provide that upon closing the Account, 13 Chase will “return the balance less any fees, setoffs, or other amounts if the balance is 14 greater than $1.” (Id. ¶ 13.) Moreover, Chase “may decline or prevent any or all 15 transactions” to and from the Account, “including refusing, freezing, reversing or 16 delaying any specific withdrawal, payment or transfer of funds” to or from the 17 Account, “or removing funds from” the Account “to hold them pending investigation 18 in one or more of” listed circumstances.2 (Id. ¶¶ 14, 25.) Identified circumstance 19 include Chase “suspect[ing] that any transaction may involve illegal activity or may 20 be fraudulent” and “reasonably believe[ing] that” restricting withdrawals “is necessary 21 to avoid a loss or reduce risk to” Chase. (Id. ¶ 14.) 22 On May 3, 2023, Markowitz deposited two checks (the “Checks”) totaling 23 $683,246.97 (the “Funds”) into his Account. (Id. ¶ 18.) The proceeds of one of the 24

25 2 Markowitz contends that Chase may only place restrictions on the Account if there are “pending transactions, the [A]ccount is overdrawn, or [the A]ccount is subject to legal process (such as 26 garnishment, attachment, execution, levy or similar order).” (SGDF ¶¶ 25, 28.) This is not what the DAAs state. For instance, the 2017 DAA states only that Chase is “not required to close” the 27 Account at Markowitz’s request under the above described circumstances. (Decl. Jane Kespradit 28 ISO Mot. (“Kespradit Decl.”) Ex. 2 (“Chase RFAs”) Ex. B (“2017 DAA”) at 13, ECF No. 32-2 (emphasis added); see Def.’s Resp. SGDF 25, 28, ECF No. 40.) 1 Checks became available in the Account on May 4, 2023, while the other became 2 available on May 12, 2023. (Id. ¶¶ 19–20.) On May 11, 2023, Chase closed the 3 Account (and Markowitz’s other Chase accounts) based on an “abusive customer” 4 case submission.3 (Id. ¶ 21.) That same day, Chase restricted the Account. (Id. ¶ 22.) 5 As part of its closure process, Chase restricts and reviews the exited customer’s 6 account to verify that the funds can be released. (Id. ¶ 28.) If such funds cannot be 7 verified, Chase may hold the amount in suspense pending verification. (Id.) 8 In a letter dated May 11, 2023, Chase notified Markowitz that it “believe[s] that 9 it’s in our mutual interest to close account(s) due to inappropriate conduct with our 10 employees.” (Id. ¶ 23.) Around two days later, Markowitz alleges that while he was 11 in a Chase branch, a Chase employee informed him that he could not make a 12 withdrawal as the Account had been closed due to his inappropriate conduct with a 13 Chase employee. (Id. ¶ 27.) 14 On May 18, 2023, in connection with the closure process, a Chase fraud 15 department employee reviewed the Account and restricted the Funds. (Id. ¶ 29.) 16 Chase purports that it restricted the Funds because it was concerned that the payee 17 name on the Checks, SureTec Insurance Company (“SureTec”), may have been 18 altered, and Chase suspended transfer of the Funds pending SureTec’s verification of 19 issuance. (Id. ¶¶ 30, 32–33.) Markowitz contends that this was a “feigned reason” for 20 Chase’s restriction of the Funds. (SGDF ¶¶ 30, 32.) 21 Chase verified the remaining Account balance (excluding the Funds) in the 22 Account and released those funds, totaling $8,791.01, to Markowitz in a May 22, 23 2023 check.4 (SUF ¶ 35.) Markowitz regularly called Chase during May and June 24

25 3 While irrelevant to the outcome of this Motion, the Court notes that Markowitz denies being abusive to any Chase employee. (SGDF ¶ 21.) 26 4 Markowitz contends that Chase “presented no evidence that it verified” the $8,791.01. (SGDF ¶ 35.) Chase has provided such evidence: a contemporaneous business record that includes an entry 27 dated May 18, 2023, stating, “Remainder of funds have been verified and approved to be released.” 28 (Def.’s Resp. SGDF ¶9; Decl. Kevin Kesterson ISO Mot. (“Kesterson Decl.”), Ex. A at 2, ECF No. 32-4.) 1 2023 to inquire about the Funds. (Decl. Philip Markowitz ISO Opp’n (“Markowitz 2 Decl.”) ¶¶ 17–18, 22, ECF No. 34-2.) 3 On May 23, 2023, Chase attempted to contact SureTec through its parent 4 company, but was informed it was outside of business hours. (SUF ¶ 36.) Between 5 July 24, 2023, and November 7, 2023, after Markowitz initiated this action, Chase 6 requested that Markowitz provide it with information that might assist in its 7 investigation of the Checks, including a contact at SureTec. (Id. ¶¶ 38–39.) 8 Markowitz did not provide Chase with the requested information. (Id. ¶ 40.) On 9 December 4, 2023, Chase sent a letter to two firms that had appeared as counsel of 10 record for SureTec in unrelated court filings to confirm whether SureTec believed the 11 Checks were authentic. (Id. ¶¶ 41–42.) On December 8, 2023, SureTec confirmed 12 that the Checks were genuine and unaltered. (Id. ¶ 43.) On or about February 27, 13 2024, Markowitz received a check from Chase in the amount of the Funds. (Id. ¶ 44.) 14 On July 6, 2023, Markowitz filed this action against Defendants Chase and 15 Claire Dawson, a Chase employee who Markowitz alleged was “the decision maker” 16 with regard to his Account, in Los Angeles County Superior Court. (Compl ¶¶ 2–3, 17 25.) Markowitz asserts four claims: (1) conversion, (2) claim and delivery, 18 (3) intentional infliction of emotional distress (“IIED”), and (4) negligent infliction of 19 emotional distress (“NIED”). (Id. ¶¶ 26–55.) Markowitz seeks consequential and 20 incidental damages, punitive and exemplary damages, attorneys’ fees, and costs. (Id., 21 Prayer for Relief). Markowitz also sought the amount of the Funds, (id.), but Chase 22 has since returned those Funds, (SUF ¶ 44). 23 Chase removed the action to federal court based on diversity jurisdiction. (See 24 NOR.) The Court granted Dawson’s motion to dismiss pursuant to Rule 12(b)(2) for 25 lack of personal jurisdiction. (Order Mot. Dismiss, ECF No. 24; Min. Order, ECF 26 No.

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

Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Scott v. Harris
550 U.S. 372 (Supreme Court, 2007)
Cynthia Lawler v. Montblanc North America, LLC
704 F.3d 1235 (Ninth Circuit, 2013)
Alpha Beta Acme Markets, Inc. v. City of Whittier
262 Cal. App. 2d 16 (California Court of Appeal, 1968)
Burch v. Regents of the University of California
433 F. Supp. 2d 1110 (E.D. California, 2006)
Hughes v. Pair
209 P.3d 963 (California Supreme Court, 2009)
Lee v. Hanley
354 P.3d 334 (California Supreme Court, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Philip Markowitz v. JPMorgan Chase Bank, N.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/philip-markowitz-v-jpmorgan-chase-bank-na-cacd-2024.