Staley v. Navy Federal Credit Union

CourtDistrict Court, S.D. New York
DecidedJune 15, 2025
Docket1:24-cv-08265
StatusUnknown

This text of Staley v. Navy Federal Credit Union (Staley v. Navy Federal Credit Union) 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
Staley v. Navy Federal Credit Union, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ANTHONY T. STALEY, Plaintiff, 24-CV-8265 (LTS) -against- ORDER OF DISMISSAL WITH LEAVE TO REPLEAD NAVY FEDERAL CREDIT UNION, Defendant. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff, who is appearing pro se, brings this action under the Court’s federal question jurisdiction, alleging that Defendant discriminated against him and failed to “provide customer service according to the banking regulatory rules.” (ECF 1 ¶ I.) By order dated February 20, 2025, the Court granted Plaintiff’s request to proceed in forma pauperis (“IFP”), that is, without prepayment of fees. For the reasons set forth below, the Court dismisses the complaint with leave to replead. 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 of the claims raised. 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. Rule 8 requires a complaint to 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 The following facts are drawn from the complaint against the Navy Federal Credit Union (“NFCU”) regarding events allegedly occurring in New York City in June 2024. Plaintiff asserts that the NFCU “falsely” made a claim of “fraud against” his account and “restrict[ed his] debit card for a year, without explaining “who or what was fraudulent.” (ECF 1 ¶ III.) Although the NFCU “clearly state[d]” that Plaintiff did not “commit fraud,” the NFCU “us[ed] fraudulent evidence from another case” to “penalize[]” him, “deleted all relevant emails and messages to appeal the decision,” and falsely claimed that Plaintiff “never file[d] an appeal when [he] did.” (Id.). Plaintiff asserts that the NFCU “singled” him out, and that an “individual inside” is “working along with an individual here in New York sending false information to NFCU, and that “[i]s part of the reason [he is] being treated the way [he is].” (Id.) Plaintiff seeks money damages. (Id.) Since filing this complaint, Plaintiff has filed multiple motions seeking various forms of relief, including service of the complaint. (ECF 7-17.)

DISCUSSION Plaintiff alleges that the NFCU discriminated against him and failed to “provide customer service according to the banking regulatory rules.” (ECF 1 ¶ I) Because Plaintiff alleges that the NFCU discriminated against him on the basis of his race, the Court construes his complaint as asserting a claim under 42 U.S.C. § 1981. Section 1981 prohibits racial discrimination in, among other things, all contractual relationships. See Rivers v. Roadway Express, Inc., 511 U.S. 298, 304 (1994).1 Making and enforcing contracts includes, “the making, performance, modification, and termination of contracts, and the enjoyment of all benefits, privileges, terms, and conditions of the contractual relationship.” 42 U.S.C. § 1981(b). Rojas v. Signature Bank, No. 18-CV-6757, 2019 WL 1333257, at *2 (E.D.N.Y. Mar. 25, 2019); Nwachukwu v. Liberty Bank, 257 F. Supp. 3d 280, 305 (D. Conn. 2017) (“Plaintiff and Defendant had a contractual relationship, as account

holder and bank respectively, and Defendant’s alleged discrimination concerned Plaintiff’s ability to make and enforce that contract, one of the activities enumerated in § 1981.”) To state a claim of discrimination under Section 1981, a plaintiff must allege facts showing: “(1) [the] plaintiff[] [is a] member[] of a racial minority; (2) [the] defendant[’s] intent to discriminate on the basis of race; and (3) discrimination concerning one of the statute’s

1 Claims under section 1981 can be brought against public or private entities, so long as the parties formed a contract. See Johnson v. City of New York, 669 F. Supp. 2d 444, 449 (S.D.N.Y. 2009); see Oliver v. Navy Fed. Credit Union, No. 23-CV-1731, 2024 WL 2786905, at *1 (E.D. Va. May 30, 2024) (describing the NFCU as “a member-owned, not-for-profit credit union that provides financial services to members of the military, veterans, and their families”). enumerated activities.” Brown v. City of Oneonta, N.Y., 221 F.3d 329, 339 (2d Cir. 2000). It “is insufficient to merely plead that race was a motivating factor in the discriminatory action.” Brown v. Montefiore Med. Ctr., No. 19-CV-11474, 2021 WL 1163797, at *5 (S.D.N.Y. Mar. 25, 2021) (citing Comcast Corp. v. Nat’l Ass’n of African Am.-Owned Media, 589 U.S. 327, 337-38

(2020)). Instead, “a plaintiff must initially plead and ultimately prove that, but for race, [he] would not have suffered the loss of a legally protected right.” Brown, 2021 WL 1163797, at *5 (S.D.N.Y. Mar. 25, 2021) (citing Comcast Corp., 589 U.S. at 337-38)).

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Related

Coppedge v. United States
369 U.S. 438 (Supreme Court, 1962)
Rivers v. Roadway Express, Inc.
511 U.S. 298 (Supreme Court, 1994)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Salahuddin v. Cuomo
861 F.2d 40 (Second Circuit, 1988)
Hill v. Curcione
657 F.3d 116 (Second Circuit, 2011)
Brown v. City Of Oneonta
221 F.3d 329 (Second Circuit, 2000)
Harris v. Mills
572 F.3d 66 (Second Circuit, 2009)
Johnson v. City of New York
669 F. Supp. 2d 444 (S.D. New York, 2009)
Cuoco v. Moritsugu
222 F.3d 99 (Second Circuit, 2000)
Nwachukwu v. Liberty Bank
257 F. Supp. 3d 280 (D. Connecticut, 2017)

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Bluebook (online)
Staley v. Navy Federal Credit Union, Counsel Stack Legal Research, https://law.counselstack.com/opinion/staley-v-navy-federal-credit-union-nysd-2025.