Subhash Dhand v. Capital One N.A.

Court of Appeals of Kentucky·Decided July 10, 2026·No. 2025-CA-1305·Unpublished

Opinion

RENDERED: JULY 10, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2025-CA-0760-MR

SUBHASH DHAND; S. DHAND M.D., INC.; SADHNA DHAND; AND SUBHASH DHAND AND SADHNA DHAND AS TRUSTEES OF THE DHAND FAMILY TRUST DATE 05/05/89 APPELLANTS

APPEAL FROM BOONE CIRCUIT COURT v. HONORABLE RICHARD A. BRUEGGEMANN, JUDGE ACTION NO. 24-CI-01972

BANK OF AMERICA N.A.; CAPITAL ONE N.A.; CENTRAL BANK & TRUST COMPANY; FIFTH THIRD BANK, N.A.; HERITAGE BANK, INC.; JPMORGAN CHASE BANK, N.A.; MERRILL LYNCH, PIERCE, FENNER & SMITH, INC.; AND WELLS FARGO BANK, N.A. APPELLEES

AND NO. 2025-CA-1305-MR

SUBHASH DHAND; S. DHAND M.D.; SADHNA DHAND; AND SUBHASH DHAND AND SADHNA DHAND AS TRUSTEES OF THE DHAND FAMILY TRUST DATE 05-05-89 APPELLANTS APPEAL FROM BOONE CIRCUIT COURT v. HONORABLE RICHARD A. BRUEGGEMANN, JUDGE ACTION NO. 24-CI-01972

CAPITAL ONE N.A. AND WELLS APPELLEES FARGO BANK, N.A.

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, KAREM, AND MCNEILL, JUDGES.

MCNEILL, JUDGE: This is a financial fraud case. The scheme targeted a

practicing physician, Dr. Dhand, and his wife, Sadhna Dhand, individually and as

trustees of the Dhand Family Trust date 05-05-89 (collectively, “Appellants”).

Individuals impersonating government officials persuaded Dr. Dhand to wire

transfer approximately $5.8 million from several bank accounts in California to

accounts in Kentucky. After discovering the loss, Appellants filed a lawsuit in

Boone County, Kentucky. Therein, they asserted claims against the alleged

-2- defrauder and various financial institutions involved in the transfer of funds (the

“Banks”).1

The Banks filed individual motions to dismiss for failure to state a

claim under CR2 12.02(f), which were granted. Appellants appealed to this Court

as a matter of right. Two dismissal orders lacked the requisite finality language.

CR 54.02(1). Appellants were ordered to show why those orders should not be

excluded. The matter was ultimately resolved by an agreed order entered by the

trial court adding the finality language, from which Appellants appealed, resulting

in two separate cases before this Court. Appellants filed a motion to consolidate,

which was granted. For the following reasons, we affirm.

STANDARD OF REVIEW

“Since a motion to dismiss for failure to state a claim upon which

relief may be granted is a pure question of law, a reviewing court owes no

deference to a trial court’s determination; instead, an appellate court reviews the

issue de novo.” Fox v. Grayson, 317 S.W.3d 1, 7 (Ky. 2010) (citation omitted).

Accordingly, “the pleadings should be liberally construed in the light most

favorable to the plaintiff, all allegations being taken as true.” Id.

1 They include the above captioned Appellees Wells Fargo, Bank of America, N.A., Merrill Lynch, Pierce, Fenner & Smith, Incorporated JP Morgan Chase Bank, N.A, Fifth Third Bank, N.A., Central Bank & Trust Co., and Heritage Bank, Inc. 2 Kentucky Rules of Civil Procedure.

-3- ANALYSIS

Appellants raise seven issues on appeal. They include various

common law negligence and statutory violations resulting in alleged damages,

including punitive damages. However, we begin with Appellants’ argument that

their complaint was timely filed within the one-year statute of limitations period.

KRS3 413.140.

We need not address that issue beyond concluding that it does not bar

the present case. Expiration of the statute of limitations was not the basis for the

trial court’s dismissal order. Moreover, it is undisputed that Appellants discovered

that they were defrauded on December 3, 2023. The present case was filed on

December 2, 2024, which is within the one-year statute of limitations. What

matters here is “knowledge that one has been wronged[,]” not “knowledge that the

wrong is actionable[.]” Wolfe v. Kimmel, 681 S.W.3d 7, 14 (Ky. 2023) (internal

quotation omitted). Thus, the present case was timely filed. The remaining issues

were addressed by the circuit court in one of its dismissal orders as follows:

[Appellants’] negligence claims fail as a matter of law because [Banks] owed no duty to the Plaintiffs, who were not its customers, and such negligence claims are displaced by Kentucky’s implementation of the Uniform Commercial Code;

[Appellants’] claim under KRS 209.030 [is] barred, because the Plaintiffs, as (1) non-residents of the

3 Kentucky Revised Statutes.

-4- Commonwealth and (2) having failed to allege that they are dysfunctioning adults unable to cope with the daily activities of life, are not a protected class for purpose of the statute;

[Appellants’] claims under KRS 365.245 fail because the reporting obligations of the statute are permissive, not mandatory, and even if they were not, [Appellants] have alleged no facts that would allow [Banks] to reasonably conclude there was any financial exploitation; and

[Appellants’] remaining claims, including their claims for punitive damages and attorneys’ fees, fail as a matter of law.[4]

Common Law Claims

The primary basis for the circuit court’s disposition is that Kentucky’s

Uniform Commercial Code Article 4A, KRS 355.4A–101 et seq., (“UCC”),

typically preempts common law negligence claims such as those raised herein.

Kentucky has “a strong policy in favor of treating the UCC as occupying the field

and displacing common-law causes of action.” Mark D. Dean, P.S.C. v.

Commonwealth Bank & Tr. Co., 434 S.W.3d 489, 505 (Ky. 2014). Indeed, “the

Code is plenary and exclusive except where the legislature has clearly indicated

otherwise.” Id. (quoting Lincoln Bank & Tr. Co. v. Queenan, 344 S.W.2d 383, 385

(Ky. 1961)). Accordingly, a common law claim is foreclosed when the UCC

4 Only the circuit court’s order granting Bank of America’s motion to dismiss contains findings. However, because the Banks’ arguments for dismissal were similar—if not identical—we will impute the court’s findings as broadly applicable.

-5- provides a comprehensive remedy for the transaction at issue. Id. at 506-07. We

agree with the Banks that the UCC displaces Appellants’ common law claims

because it provides a comprehensive remedy for the transfer of funds. Yet, no

UCC violation is alleged here. See KRS 355.4A-202(1) (“A payment order

received by the receiving bank is the authorized order of the person identified as

sender if that person authorized the order . . . .”); KRS 355.4A-204(1)(a)

(describing circumstances for refunds of payment orders that are “not authorized

. . . under KRS 355.4A-202”).

To be clear, Appellants’ central argument on appeal is that the Banks

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Subhash Dhand v. Capital One N.A., (Ky. Ct. App. 2026).

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