Rogers v. Capital One Bank (USA), N.A.

CourtDistrict Court, N.D. Ohio
DecidedMarch 14, 2024
Docket3:23-cv-02392
StatusUnknown

This text of Rogers v. Capital One Bank (USA), N.A. (Rogers v. Capital One Bank (USA), N.A.) 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
Rogers v. Capital One Bank (USA), N.A., (N.D. Ohio 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO WESTERN DIVISION

Andrew Rogers, Case No. 3:23-cv-2392-JGC Plaintiff,

v. ORDER

Capital One et al.,

Defendant.

This is a case contesting Defendant Capital One’s closure of Plaintiff Andrew Rogers’ credit card account. Plaintiff is pro se. Defendant Capital One Bank (USA), N.A. is the issuing bank for the subject credit card. (Doc. 1, pgID 1). Defendants Richard Fairbank and Andrew Young are Capital One’s CEO and CFO, respectively. (Id.). Before me are two dueling motions: (1) Plaintiff’s Motion to Deny Defendant’s Motion to Transfer to Federal Court. (Doc. 7); and (2) Capital One’s Motion to Dismiss Plaintiff’s Amended Complaint (Doc. 6). I construe Plaintiff’s motion as a 28 U.S.C. § 1447(c) motion to remand to state court. See Stanley v. Vining, 602 F.3d 767, 771 (6th Cir. 2010) (citing Franklin v. Rose, 765 F.2d 82, 85 (6th Cir.1985)). For the reasons below, I grant Plaintiff’s Motion and remand the case back to the Napoleon Municipal Court in Napoleon, Ohio. Because I lack jurisdiction, I deny without prejudice Defendants’ Motion to Dismiss. Background Plaintiff’s Amended Complaint is difficult to understand. The Complaint contains many haphazard citations to various legal authorities of dubious relevance here. The Amended Complaint does not do the most important thing: Tell me and the Defendants what happened and what injury occurred. As far as I can tell, Capital One closed Plaintiff’s credit card account. (Doc. 1-3, pgID 13). Capital One apparently did so because Plaintiff stopped paying his credit card bill. (See id.,

pgID 29). Plaintiff did not make any money payment. Instead, Plaintiff mailed a “note”1 to Capital One. (Id., pgID 24). Plaintiff contends that this letter somehow counted as full payment of his credit card debt. In Plaintiff’s own words in his letter to Capital One: “Please transfer the positive value of this bearer security to the principal to set-off the account and bring it down to zero.” (Id.). Capital One of course did not accept Plaintiff’s mailed letter as somehow being a form of payment. But Plaintiff believes this was wrong. He filed suit, seeking to reopen his credit card account and seeking money damages. (Id., pgID 18). Plaintiff originally filed this case in the small claims division of the Napoleon Municipal

Court in Napoleon, Ohio. He based his complaint on state contract law only. (Doc. 1-1). The municipal court transferred the case from the small claims division to its civil division. (Doc. 1- 2). Shortly after transfer, on November 29, 2023, Plaintiff chose to amend his complaint. (Doc. 1-4).

1 What Plaintiff calls a “note” is a letter that Plaintiff mailed to Capital One. Plaintiff appears to be under the misguided assumption that letters he writes somehow are “bank notes” or “promissory notes.” This assumption is incorrect. Plaintiff is not a bank or a mint, and Plaintiff made no promise, enforceable or otherwise, in his letter. His mailed letter is simply that—a letter. On December 15, 2023, Defendants timely removed to federal court. According to Defendants’ Notice of Removal, Plaintiffs’ amended Complaint added federal claims over which I have original jurisdiction, thus making removal proper under 28 U.S.C. § 1441(c). Discussion

Under 28 U.S.C. § 1441, a defendant may remove a civil action “from state court to federal court when the action initiated in state court is one that could have been brought, originally, in a federal district court.” Lincoln Prop. Co. v. Roche, 546 U.S. 81, 83 (2005). I must strictly construe the removal statute in favor of Ohio’s “important interest in the independence of their courts.” See First Nat. Bank of Pulaski v. Curry, 301 F.3d 456, 462 (6th Cir. 2002); accord Brierly v. Alusuisse Flexible Packaging, Inc., 184 F.3d 527, 534 (6th Cir. 1999) (“[W]e are mindful that the statutes conferring removal jurisdiction are to be construed strictly because removal jurisdiction encroaches on a state court’s jurisdiction.”). In the interest of comity and federalism, I exercise jurisdiction “only when it is clearly established, and any ambiguity regarding the scope of [the removal statute] should be resolved in favor of remand to

the state courts.” Brierly, supra, 184 F.3d at 534; see also Stamatopoulos v. All Seasons Contracting, Inc., 2012 WL 5272090, at *1 (N.D. Ohio Oct. 23, 2012) (Wells, J.) (“[A]ny doubt concerning the propriety of removal should be resolved in favor of remand.”) (citing Union Planters Nat–Bank of Memphis v. CBS, Inc., 557 F.2d 84, 89 (6th Cir.1977)). Removal jurisdiction can be based on either the federal courts’ diversity jurisdiction under 28 U.S.C. § 1332 or its federal question jurisdiction under 28 U.S.C. § 1331. Defendants argue that I have federal question jurisdiction because of the citations to federal statutes Plaintiff added to his Amended Complaint. I thus limit my analysis to federal question jurisdiction. 1. Federal Question Jurisdiction Congress granted federal district courts original jurisdiction over “all civil actions arising under the Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. Thus, I have federal question jurisdiction in cases showing “either that federal law creates the cause of action

or that the plaintiffs right to relief necessarily depends on resolution of a substantial question of federal law.” Thornton v. Sw. Detroit Hosp., 895 F.2d 1131, 1133 (6th Cir. 1990) (quoting Franchise Tax Bd. of State of Cal. v. Constr. Laborers Vacation Tr. for S. Cal., 463 U.S. 1, 27– 28 (1983). I evaluate claims removed based on federal question jurisdiction under the “well- pleaded complaint” rule. Eastman v. Marine Mech. Corp., 438 F.3d 544, 550 (6th Cir. 2006). “[The well-pleaded complaint] rule provides that federal jurisdiction exists only when a federal question is presented on the face of the plaintiff's properly pleaded complaint.” Id. (citing Caterpillar Inc. v. Williams, 482 U.S. 386, 392 (1987)) (internal quotation marks omitted). A plaintiff gets to decide for himself on what law he will base his complaint. Since the plaintiff is the decision-maker, and not any defendant, “the fact that a claim could be stated under

federal law does not prevent him from stating it under state law only.” Id. 2.

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