Smith v. JPMorgan Chase Bank, N.A.

CourtDistrict Court, S.D. California
DecidedJune 2, 2025
Docket3:24-cv-01287
StatusUnknown

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

Bluebook
Smith v. JPMorgan Chase Bank, N.A., (S.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 MARCIA SMITH, Case No.: 24-CV-1287 JLS (DTF)

12 Plaintiff, ORDER: 13 v. (1) DENYING PLAINTIFF’S 14 JPMORGAN CHASE BANK, N.A., a MOTION TO REMAND TO STATE business entity; SADAF ZADEH, an 15 COURT; individual; ANGEL ARENAS, an

16 individual; and DOES 1–10, inclusive, (2) OVERRULING PARTIES’ 17 Defendants. EVIDENTIARY OBJECTIONS;

18 (3) GRANTING DEFENDANT 19 JPMORGAN CHASE BANK, N.A.’S MOTION TO COMPEL 20 ARBITRATION; AND 21 (4) STAYING ACTION PENDING 22 COMPLETION OF ARBITRATION 23 PROCEEDINGS

24 (ECF Nos. 9, 10, 17-3, 19-6) 25

26 Presently before the Court are Plaintiff Marcia Smith’s (“Plaintiff”) Motion to 27 Remand to State Court (“Remand Mot.,” ECF No. 9) and Memorandum of Points and 28 Authorities in support thereof (“Remand Mem.,” ECF No. 9-1). Defendant JPMorgan 1 Chase Bank N.A. (“Defendant” or “Chase”) filed an Opposition to Plaintiff’s Motion for 2 Remand (“Remand Opp’n,” ECF No. 14), to which Plaintiff filed a Reply (“Remand 3 Reply,” ECF No. 15). 4 Also before the Court is Chase’s Motion to Compel Arbitration (“Arb. Mot.,” ECF 5 No. 10), along with Declarations of William A. Garrett (“Garrett Decl.,” ECF No. 10-1) 6 and Halie Williams (“Williams Decl.,” ECF No. 10-2) in support of Chase’s Motion to 7 Compel Arbitration. Plaintiff then filed an Opposition to the Arbitration Motion (“Arb. 8 Opp’n,” ECF No. 17), along with Declarations of Plaintiff Marcia Smith (“Smith Decl.,” 9 ECF No. 17-1) and Caleb Logan (“Logan Decl.,” ECF No. 17-2) in support of Plaintiff’s 10 Opposition. Plaintiff also filed Objections to Chase’s Declarations in Support of its Motion 11 to Compel Arbitration (“Pl.’s Arb. Objs.,” ECF No 17˗3). Thereafter, Chase submitted a 12 Reply (“Arb. Reply,” ECF No. 19), Supplemental Declaration of Halie Williams in Support 13 of Chase’s Motion to Compel Arbitration (“Suppl. Williams Decl.,” ECF No 19-1), 14 Responses to Plaintiff’s Evidentiary Objections to Declarations in Support of the Motion 15 to Compel Arbitration (“Resp. to Pl.’s Arb. Objs.,” ECF No. 19-5), and Evidentiary 16 Objections to Plaintiff’s Declarations (“Chase’s Arb. Objs.,” ECF No. 19-6). 17 Having carefully considered the Parties’ arguments, the evidence, and the law, the 18 Court DENIES Plaintiff’s Remand Motion, OVERRULES the Parties’ Evidentiary 19 Objections, GRANTS Chase’s Arbitration Motion, and STAYS this action pending the 20 completion of arbitration proceedings. 21 BACKGROUND 22 I. Factual Background 23 On June 20, 2024, Plaintiff initiated this action in California Superior Court against 24 Chase and two of its employees, Defendants Sadaf Zadeh and Angel Arenas (collectively, 25 the “Individual Defendants”). In her Complaint, Plaintiff alleges all three Defendants 26 assisted in financial elder abuse in violation of California Welfare and Institutions Code 27 § 15610.30. Specifically, Plaintiff alleges she was the victim of an “Amazon” scam 28 perpetrated by unknown individuals who convinced her to withdraw funds from her Chase 1 account ending in -8297 (“Account”) and to deposit them into a Bitcoin ATM, as well as 2 wire funds internationally to a bank account in Hong Kong in August 2023. Compl. 3 ¶¶ 25–34; Declaration of Kevin Kesterson in Support of Notice of Removal (“Kesterson 4 Decl.”), ECF No. 1-3 ¶ 3, Ex. A. 5 Plaintiff claims the Individual Defendants knew or should have known she was being 6 scammed when she sought to complete a $37,000 wire transfer.1 See Compl. ¶¶ 43–44, 7 46–48. Plaintiff also alleges, inter alia, that Chase had “actual knowledge of the scam” 8 after she reported it, yet withheld its assistance until it was too late to do anything. See id. 9 ¶ 51. The Complaint contains a second cause of action as to Chase alone for violations of 10 California’s Unfair Competition Law. 11 II. Procedural Background 12 On July 24, 2024, Chase removed this action to federal court pursuant to 13 12 U.S.C. § 632 and 28 U.S.C. § 1332(a), as well as 28 U.S.C. §§ 1441 and 1446, based 14 upon statutory provisions providing for federal jurisdiction in matters related to foreign 15 banking transactions. Notice of Removal (“Notice”) at 1, ECF No. 1. In the Notice, Chase 16 provides two grounds for removal. Chase first cites the Edge Act, which grants federal 17 courts subject matter jurisdiction over civil suits “to which any corporation organized under 18 the laws of the United States” is a party and that “aris[e] out of transactions involving 19 international or foreign banking.” 12 U.S.C. § 632. Chase notes that it is such a federally 20 chartered corporation and claims this case involves a foreign banking transaction because 21 the recipient of the alleged wire transfer was located abroad. Notice at 3–4. In the 22 alternative, Chase asserts diversity jurisdiction pursuant to 28 U.S.C. § 1332(a). Chase 23 tacitly admits the Individual Defendants are not diverse from Plaintiff but argues the Court 24 need not consider their citizenship because both are “fraudulently joined.” Id. at 4. 25 On July 31, 2024, the Court ordered Chase to show cause as to why the action should 26

27 1 Plaintiff also seeks to recover for a $35,000 cash withdrawal that resulted from the same scam the day 28 before the wire transfer took place. See Compl. ¶¶ 27–31. Neither of the Individual Defendants appear 1 not be remanded for lack of subject matter jurisdiction. ECF No. 4 (“OSC”). First, the 2 Court noted concerns with finding jurisdiction appropriate here under the Edge Act. The 3 Court recognized that removal jurisdiction is appropriate under the Edge Act “when: (1) the 4 lawsuit is a civil action in law or equity; (2) a corporation organized under the laws of the 5 United States is a party; and (3) the lawsuit arises out of transactions involving 6 international or foreign banking.” OSC at 3 (citing Kim v. Wells Fargo, N.A., No. 21-CV- 7 05405-JD, 2021 WL 5996486, at *2 (N.D. Cal. Dec. 20, 2021)). While acknowledging the 8 first two requirements were met, the Court expressed reservation about whether the action 9 “arises out of” the international wire transfer. OSC at 4–5. 10 Next, the Court raised its doubts as to Chase’s alternative assertion of diversity 11 jurisdiction, on the basis that the Individual Defendants’ citizenship, which would 12 otherwise destroy diversity, should not be considered because they were fraudulently 13 joined in the action. Id. at 5–8. 14 On August 14, 2024, Chase filed its Response to the Order to Show Cause Re 15 Removal (“Resp. to OSC,” ECF No. 5), asserting the action was properly removed under 16 the Edge Act, as this action “arises out of” an international wire transfer. Resp. to OSC. 17 at 3–10. Chase explained that Plaintiff’s “claims are founded on her accusation Chase 18 should have known about the purported scam, including because Plaintiff requested the 19 international wire transfer.” Id. at 6 (emphasis in original) (citing Compl. ¶ 48(c)). 20 Further, Chase asserted “there is indisputable evidence that Plaintiff directed the wire to 21 Hong Kong and that it represents more than 50% of the amount at issue.” Id. at 6–7 (citing 22 Keterson Decl., Ex. A at 2).

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Bluebook (online)
Smith v. JPMorgan Chase Bank, N.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-jpmorgan-chase-bank-na-casd-2025.