Sinai v. Del-One Federal Credit Union

CourtDistrict Court, D. Delaware
DecidedApril 11, 2025
Docket1:25-cv-00153
StatusUnknown

This text of Sinai v. Del-One Federal Credit Union (Sinai v. Del-One Federal Credit Union) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sinai v. Del-One Federal Credit Union, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

_ FOR THE DISTRICT OF DELAWARE ALEXANDER SINAI, ) ) Plaintiff, ) ) Vv. ) Civ. No. 25-153-CFC ) DEL-ONE FEDERAL CREDIT ) UNION, et al., ) ) Defendants. ) MEMORANDUM OPINION

Alexander Sinai, Wilmington, Delaware — Pro Se Plaintiff Elio Battista, Jr., and Madeline Susan Carlson, PARKOWSKI, GUERKE & SWAYZE, P.A., Dover, Delaware — Counsel for Defendants Del-One Federal Credit Union and John Chartrand

April 11, 2025 Wilmington, Delaware

be a I. INTRODUCTION On February 7, 2025, Plaintiff Alexander Sinai, of Wilmington, Delaware, filed this civil action pro se against Defendants Del-One Federal Credit Union and John Chartrand, of Dover, Delaware. (D.I. 1.) Plaintiff has been granted leave to proceed in forma pauperis. (D.1.8.) The Court will grant Plaintiff's motion to amend the Amended Complaint, and the Second Amended Complaint will be the operative pleading. (D.I. 7.) The Court proceeds to review and screen the Second Amended Complaint pursuant to 28 U.S.C. § 1915(e)(2)(b). H. BACKGROUND The Second Amended Complaint asserts that this case raises a federal question that falls under the purview of the Bureau of Consumer Financial Protection, and not the Federal Trade Commission, as was indicated when this civil action was initiated. (D.I. 7 at 1.) The Second Amended Complaint also asserts that this case raises questions, involving breach of contract, misrepresentation, fair dealing, and unfair practices, under Delaware State law and the Uniform Commercial Code. (/d. at 1-2.) The following facts are taken from the Second Amended Complaint and assumed to be true for purposes of screening this case. See Shorter v. United States,

12 F.4th 366, 374 (3d Cir. 2021). In 2024, Defendant Chartrand, the Chief Banking Officer for Defendant Del-One, represented to Plaintiff, “Yes, we can amend the agreements,” during a discussion of loans agreements for the reorganization of Plaintiff's business. (D.I. 7-1 at 1-2.) Defendant Del-One then “initiated an unauthorized wire transfer” and “exercised the right of setoff.” (Jd. at 3.) The Second Amended Complaint provides no additional factual information regarding the alleged agreement and transaction. Il. SCREENING OF COMPLAINT A federal court may properly dismiss an action sua sponte under the screening provisions of 28 U.S.C. §§ 1915(e)(2)(B) and 1915A if “the action is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief.” Ball v. Famiglio, 726 F.3d 448, 452 (3d Cir. 2013) (quotation marks omitted); see also 28 U.S.C. § 1915(e)(2) (in forma pauperis actions). The Court must accept all factual allegations in a complaint as true and take them in the light most favorable to a pro se plaintiff. See Phillips v. County of Allegheny, 515 F.3d 224, 229 (3d Cir. 2008). Because Plaintiff proceeds pro se, his pleading is liberally construed and his Complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007).

A complaint is not automatically frivolous because it fails to state a claim. See Dooley v. Wetzel, 957 F.3d. 366, 374 (3d Cir. 2020). Rather, a claim is deemed frivolous only where it relies on an “‘indisputably meritless legal theory’ or a ‘clearly baseless’ or ‘fantastic or delusional’ factual scenario.’” Jd. The legal standard for dismissing a complaint for failure to state a claim pursuant to § 1915(e)(2)(B)(ii) is identical to the legal standard used when ruling on Rule 12(b)(6) motions. Tourscher v. McCullough, 184 F.3d 236, 240 (3d Cir. 1999). A well-pleaded complaint must contain more than mere labels and conclusions. See Ashcroft v. Iqbal, 556 U.S. 662 (2009); Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007). A plaintiff must plead facts sufficient to show that a claim has substantive plausibility. See Johnson v. City of Shelby, 574 U.S. 10, 12 (2014) (per curiam). A complaint may not be dismissed, however, for imperfect statements of the legal theory supporting the claim asserted. See id. at 11. A court reviewing the sufficiency of a complaint must take three steps: (1) take note of the elements the plaintiff must plead to state a claim; (2) identify allegations that, because they are no more than conclusions, are not entitled to the assumption of truth; and (3) when there are well-pleaded factual allegations, assume their veracity and then determine whether they plausibly give rise to an entitlement to relief. Connelly v. Lane Constr. Corp., 809 F.3d 780, 787 (3d Cir. 2016).

Elements are sufficiently alleged when the facts in the complaint “show” that the plaintiff is entitled to relief. gbal, 556 U.S. at 679 (quoting Fed. R. Civ. P. 8(a)(2)). Deciding whether a claim is plausible will be a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. IV. DISCUSSION Employing the less stringent standard afforded to pro se litigants, see Erickson, 551 U.S. at 94, the Court finds that the claims asserted in the Second Amended Complaint are outside the Court’s subject matter jurisdiction, warranting dismissal without prejudice, which will allow Plaintiff to bring his claims before an appropriate court. Although the Second Amended Complaint asserts that it raises a federal question, pursuant to the Consumer Financial Protection Act (CFPA), numerous

courts have held that there is no private right of action under the CFPA. See Conway v. U.S. Bank, Nat’l Ass’n, No. 18-4916, 2018 WL 6417346, at *3 (E.D. Pa. Dec. 6, 2018) (collecting pertinent cases and holding that “there is no private right of action under the [CFPA]; the Act is enforced only by the Bureau of Consumer Financial Protection”); see also Wisniewski v. Rodale, Inc., 510 F.3d 294, 301 (3d Cir.2007) (explaining that congressional intent is crucial in determining whether a statute includes an implied private right of action); ¢f Dhade v. Huntington Learning Ctr.,

414 F. Supp. 3d 703, 707 (D. Del. 2019) (finding, in a separate context, that the CFPA did not expand plaintiffs private right of action). The existence of a private cause of action is a “prerequisite for finding federal question jurisdiction.” Alexander v. Sandoval, 532 U.S. 275, 286 (2001) (“private rights of action to enforce federal law must be created by Congress”); Smith v. Industrial Valley Title Ins.

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Sinai v. Del-One Federal Credit Union, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sinai-v-del-one-federal-credit-union-ded-2025.