Stephen Lohbeck v. JPMorgan Chase Bank, N.A.

CourtDistrict Court, E.D. California
DecidedApril 6, 2026
Docket2:25-cv-03616
StatusUnknown

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

Bluebook
Stephen Lohbeck v. JPMorgan Chase Bank, N.A., (E.D. Cal. 2026).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 STEPHEN LOHBECK, No. 2:25-cv-3616 DAD AC PS 12 Plaintiff, 13 v. ORDER and FINDINGS AND RECOMMENDATIONS 14 JPMORGAN CHASE BANK, N.A., 15 Defendant. 16 17 Defendants removed this case from Sacramento County Superior Court on December 15, 18 2025. ECF No. 1. Plaintiff is proceeding in pro se, and pre-trial proceedings are accordingly 19 referred to the undersigned pursuant to Local Rule 302(c)(21). Defendant filed a motion to 20 dismiss. ECF No. 5. Plaintiff opposed the motion (ECF No. 8) and filed a motion to remand to 21 state court (ECF No. 4). Plaintiff then filed a second motion to remand (ECF No. 10), a motion to 22 set a status conference (ECF No. 11), a request for motion calendar (ECF No. 12), and two 23 motions for leave to file a sur-reply (ECF Nos. 14, 16). 24 On January 5, 2026, plaintiff filed a First Amended Complaint. (ECF No. 18). The filing 25 of the First Amended Complaint has rendered moot defendant’s initial motion to dismiss, 26 plaintiff’s motions to remand, plaintiff’s motions to file sur-replies, and plaintiff’s requests for 27 hearings. Accordingly, it is hereby ORDERED that the motions at ECF Nos. 4, 5, 10, 11, 12, 14, 28 and 16 are DENIED as MOOT. 1 Shortly after filing the operative First Amended Complaint, plaintiff filed a motion to 2 remand. ECF No. 20. Plaintiff filed a subsequent motion to remand and for sanctions (ECF No. 3 29) and another request for sanctions (ECF No. 32). The court has reviewed the motions for 4 sanctions (ECF Nos. 29 and 32) and finds them meritless on their face. The motions for sanctions 5 are accordingly DENIED. 6 The court has also reviewed the motion to remand (ECF No. 20) and recommends for the 7 reasons set forth below that this motion be DENIED. 8 Defendant responded to the First Amended Complaint with a Motion to Dismiss. ECF 9 No. 25. Plaintiff opposed the motion. ECF No. 31. For the reasons set forth below, the 10 undersigned recommends the motion to dismiss be GRANTED with partial leave to amend. 11 I. The Complaint 12 The operative First Amended Complaint (“FAC”) relates to alleged violations of law in 13 defendant Chase’s handling of Automated Clearing House (“ACH”) debit transactions and 14 overdraft fee assessments that occurred between January 12, 2022, and December 15, 2025. ECF 15 No. 18 at 1. The FAC states that “This Court has subject matter jurisdiction under 28 U.S.C. 16 §1331 because Plaintiff asserts claims arising under federal law.” Id. 17 The FAC alleges as follows. Plaintiff maintained a personal checking account with Chase 18 during the period of January 12, 2022, through December 15, 2025. ECF No. 1 at 2. During this 19 period, Chase repeatedly authorized and paid ACH debit transactions presented against plaintiff’s 20 account despite insufficient funds. Id. Plaintiff did not opt into any overdraft program 21 authorizing Chase to pay ACH debits against insufficient funds for the purpose of generating 22 overdraft fees. Id. Chase’s internal systems allowed ACH debits to be paid even when the 23 account balance was negative. Id. After paying these ACH debits, Chase immediately assessed 24 overdraft fees to plaintiff’s account, often assessing multiple fees in a single day. Plaintiff alleges 25 the overdraft fees were not caused by his own actions, but by Chase’s discretionary decision to 26 pay ACH debits instead of declining them. Id. 27 Plaintiff alleges Chase’s conduct created a cycle in which: (1) an ACH debit was 28 presented; (2) Chase paid the debit despite insufficient funds; (3) Chase charged an overdraft fee; 1 (4) the fee deepened the negative balance; (5) subsequent ACH debits triggered additional fees. 2 Id. at 2. Plaintiff alleges that Chase did not provide clear or conspicuous disclosures informing 3 plaintiff that it would intentionally pay ACH debits against insufficient funds and then charge 4 overdraft fees, and so plaintiff reasonably expected that ACH debits would be declined when 5 insufficient funds were available. Id. at 2-3. Further, plaintiff alleges that his account statements 6 did not accurately reflect how overdraft fees were being generated. Id. at 3. 7 Plaintiff alleges he incurred substantial financial loss due to defendant’s actions, including 8 “hundreds or thousands of dollars in overdraft fees.” ECF No. 18 at 3. Plaintiff alleges 14 causes 9 of action, including: (1) breach of contract; (2) negligence; (3) unfair business practices; (4) 10 intentional infliction of emotional distress; (5) negligent infliction of emotional distress; (6) 11 breach of implied covenant of good faith and fair dealing; (7) Regulation E; (8) conversion; (9) 12 unjust enrichment; (10) fraud/deceit; (11) constructive fraud; (12) accounting; (13) declaratory 13 relief; and (14) injunctive relief. Id. at 3-6. Plaintiff requests unspecified compensatory damages, 14 statutory damages, punitive damages, restitution, injunctive relief, and declaratory relief. Id. at 6. 15 Plaintiff attaches bank statements to the FAC, one of which shows a “year-to-date” accounting of 16 overdraft fees for 2025 as $925.00 paid, and $442.00 refunded. Id. at 13. 17 II. Motion to Remand 18 A defendant who is sued in state court may remove to the appropriate federal district court 19 any civil action over which the district courts have original jurisdiction. See 28 U.S.C. § 1441(a). 20 “Federal courts are courts of limited jurisdiction.” Kokkonen v. Guardian Life Ins. Co. of Am., 21 511 U.S. 375, 377 (1994). In 28 U.S.C. §§ 1331 and 1332(a), “Congress granted federal courts 22 jurisdiction over two general types of cases: cases that ‘aris[e] under’ federal law, § 1331, and 23 cases in which the amount in controversy exceeds $ 75,000 and there is diversity of citizenship 24 among the parties, § 1332(a). These jurisdictional grants are known as ‘federal-question 25 jurisdiction’ and ‘diversity jurisdiction, respectively.” Home Depot U. S. A., Inc. v. Jackson, 587 26 U.S. 435, 437 (2019). Defendants removed this case from state court on the basis that there is 27 diversity jurisdiction. ECF No. 1 at 2. Defendant asserted the amount in controversy exceeded 28 //// 1 the $75,000.00 threshold because, in the operative state court complaint, plaintiff purported to 2 seek $30,000,000 in damages. ECF Nos. 1 at 3; 1-1 at 15. 3 “Under § 1447(c), the district court must remand ‘[i]f at any time before final judgment it 4 appears that the district court lacks subject matter jurisdiction[.]’ ” Smith v. Mylan Inc., 761 F.3d 5 1042, 1044 (9th Cir. 2014). “The general rule governing removal of actions from the state court 6 to federal court is that for a district court to have federal question removal jurisdiction, a federal 7 cause of action must appear on the face of the complaint.” Felton v. Unisource Corp., 940 F.2d 8 503, 506 (9th Cir. 1991) (citations omitted). Although original complaint did not contain a 9 federal claim, the FAC expressly states that this court has jurisdiction because there is a federal 10 claim. ECF No. 18 at 1. Defendant now points to plaintiff’s inclusion of a federal claim as a 11 basis for jurisdiction, and continues to contend there is diversity jurisdiction because “Plaintiff 12 admits he is a citizen of California (ECF No. 29 at p. 4), and with respect to its own citizenship, 13 Chase has satisfied its burden that it is a citizen of Ohio with ample evidence and case law.” ECF 14 No.

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Bluebook (online)
Stephen Lohbeck v. JPMorgan Chase Bank, N.A., Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephen-lohbeck-v-jpmorgan-chase-bank-na-caed-2026.