The Haitian Diaspora Political Action Committee, et al. v. The American Red Cross, et al.

CourtDistrict Court, S.D. Florida
DecidedOctober 16, 2025
Docket1:24-cv-24617
StatusUnknown

This text of The Haitian Diaspora Political Action Committee, et al. v. The American Red Cross, et al. (The Haitian Diaspora Political Action Committee, et al. v. The American Red Cross, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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The Haitian Diaspora Political Action Committee, et al. v. The American Red Cross, et al., (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-24617-CIV-ALTONAGA/Reid

THE HAITIAN DIASPORA POLITICAL ACTION COMMITTEE, et al.,

Plaintiffs, v.

THE AMERICAN RED CROSS, et al.,

Defendants. __________________________________/

ORDER THIS CAUSE came before the Court upon Defendants, The American Red Cross (the “Red Cross”), Gail J. McGovern (“CEO McGovern”), Cliff Holtz, and The Board of Directors of the Red Cross’s (the “Board[’s]”)1 Motion to Dismiss the Third Amended Class Action Complaint [ECF No. 69]. Plaintiffs, Nathaniel Ballantyne, Cridikel Truthbay, Renee Hasler, Darlene P. Licin, Alix Pierre, and Frantz Saint Fort, filed a Response [ECF No. 76]; to which Defendants filed a Reply [ECF No. 77]. Plaintiffs also filed a Sur-Reply [ECF No. 83]; and Defendants filed a Sur- Sur-Reply [ECF No. 88]. The Court has reviewed the Third Amended Class Action Complaint (“TAC”) [ECF No. 68], the parties’ written submissions, the record, and applicable law. For the following reasons, the Motion is granted. I. BACKGROUND This putative class action stems from allegations that Defendants — the Red Cross and its leadership — mismanaged and misappropriated over $500 million in charitable donations and an

1 The Red Cross does not have a Board of Directors; it has a Board of Governors. (See Mot. 5 n.1). additional $30 million in funding from the U.S. Agency for International Development (“USAID”), all of which were intended for relief efforts in Haiti after the January 12, 2010 earthquake and ensuing disasters. (See TAC ¶¶ 1–3, 17–18, 20, 48–50, 59, 109–12). Plaintiffs “seek[] to hold [] Defendants accountable” for an alleged “systemic pattern of fraud, misrepresentation, and unjust enrichment.” (Id. 6 (alterations added)).2 The Court previously

dismissed Plaintiffs’ First Amended Complaint (“FAC”) [ECF No. 17] and Second Amended Complaint (“SAC”) [ECF No. 63] without prejudice, affording Plaintiffs one final opportunity to amend. (See April 1, 2025 Order [ECF No. 62]; June 12, 2025 Order [ECF No. 67]). Plaintiffs did so with their Third Amended Complaint. By way of brief background, “[o]n January 12, 2010, a 7.0-magnitude earthquake struck southern Haiti, toppling buildings and power lines, resulting in widespread devastation” and loss of life. (TAC ¶¶ 3–4 (alteration added); see also id. 3 n.2). In its aftermath, the Red Cross launched a global fundraising campaign, vowing to rebuild Haiti with homes, roads, and essential relief services. (See id. 4–5, ¶¶ 6–7). CEO McGovern “publicly announced that the [Red Cross]

organization stood ready to raise funds to assist Haiti in its recovery.” (Id. ¶ 5 (alteration added)). Within a week of the disaster, the Red Cross circulated footage of Haiti’s destruction to media outlets to allegedly “manipulate and pressure individuals into contributing as much as possible.” (Id. ¶ 1; see also id. ¶¶ 111, 113). The organization assured donors — through television, online ads, and public statements — that their donations would aid earthquake victims and the Haitian people. (Id. ¶ 2; see also id. ¶¶ 9, 128–29). Yet, $150 million went to cover the Red Cross’s own financial deficit and another $400 million went to unrelated projects. (See id. ¶ 13; see also id. ¶¶ 17, 109, 138, 164). The alleged diversion of funds, Plaintiffs claim, crippled

2 The Court uses the pagination generated by the electronic CM/ECF database, which appears in the headers of all court filings. recovery efforts; and critical infrastructure projects — including road rehabilitation and sanitation improvements — were “either severely delayed or never implemented.” (Id. ¶ 27; see also id. ¶ 28). Around this time, USAID awarded the Red Cross a $14 million grant “to provide urban

planning assistance, expand infrastructure services, and promote safer housing construction in Canaan, Haiti.” (Id. 5). According to Plaintiffs, these projects were unsuccessful, and the funds from the USAID grant “were fraudulently claimed and disbursed based on false certifications that the required work in Canaan had been completed.” (Id.; see also id. ¶¶ 18–23, 96–103). Significant portions of the promised infrastructure were either not constructed or left grossly incomplete. (See id.). Plaintiffs bring this putative class action against Defendants on behalf of two subclasses. (See id. 4, ¶¶ 38–42). The first is a Class of Donors, comprising thousands of individuals who donated to the Red Cross between 2010 and 2024 in the belief that their contributions would aid Haiti’s earthquake relief efforts (“Donor Plaintiffs”). (See id.). The second is a Class of

Beneficiaries, consisting of the alleged intended third-party beneficiaries of the USAID-funded “Canaan Reconstruction Project” (“Beneficiary Plaintiffs”). (See id.).3 In their Third Amended Complaint, Plaintiffs assert 22 claims. (See generally id.). The Donor Plaintiffs assert nine claims against the Red Cross, CEO McGovern, and Holtz: fraud involving solicitations for donations (Count I) (see id. ¶¶ 127–43); breach of implied contract (Count III) (see id. ¶¶ 157–70); breach of implied covenant of good faith and fair dealing (Count

3 Named Plaintiffs Ballantyne, Hasler, Licin, and Truthbay seek to represent the Class of Donors as the “Donor Plaintiffs”; while Saint Fort seeks to represent the Class of Beneficiaries as the “Beneficiary Plaintiff.” (See TAC ¶¶ 38–42). Pierre appears only in the Third Amended Complaint’s caption and other allegations that lump Pierre as a “Plaintiff” alongside Ange Carmel Marie Fontilus and Eric Placide. (See generally id. ¶¶ 147, 173, 194, 239). V) (see id. ¶¶ 184–92); conversion/theft/embezzlement (Count IX) (see id. ¶¶ 231–37); intentional misrepresentation (Count XI) (see id. ¶¶ 247–57); civil conspiracy (Count XIII) (see id. ¶¶ 270– 77); intentional infliction of emotional distress (Count XVII) (see id. ¶¶ 310–15); negligent infliction of emotional distress (Count XIX) (see id. ¶¶ 326–36); and fraudulent conveyance

(Count XXI) (see id. ¶¶ 347–57). The Donor Plaintiffs additionally bring a claim of negligent hiring, training, and supervision against the Red Cross and the Board (Count XV) (see id. ¶¶ 287– 97); and a claim of unjust enrichment against the Red Cross (Count VII) (see id. ¶¶ 204–16). The Beneficiary Plaintiff asserts nine claims against the Red Cross, CEO McGovern, and Holtz: fraud involving the agreement with USAID funds (Count II) (see id. ¶¶ 144–56); breach of contract (Count IV) (see id. ¶¶ 171–83); breach of implied covenant of good faith and fair dealing (Count VI) (see id. ¶¶ 193–203); conversion/theft/embezzlement (Count X) (see id. ¶¶ 238–46); intentional misrepresentation (Count XII) (see id. ¶¶ 258–69); civil conspiracy (Count XIV) (see id. ¶¶ 278–86; intentional infliction of emotional distress (Count XVIII) (see id. ¶¶ 316–25); negligent infliction of emotional distress (Count XX) (see id. ¶¶ 337–46); and fraudulent

conveyance (Count XXI) (see id. ¶¶ 358–64). The Beneficiary Plaintiff additionally asserts one claim of unjust enrichment against the American Red Cross (Count VII) (see id. ¶¶ 217–30); and one claim of negligent hiring, training, and supervision against the Red Cross and the Board (Count XVI) (see id. ¶¶ 298–309). Defendants move to dismiss the Third Amended Complaint under Federal Rule of Civil Procedure 12(b)(1), asserting both facial and factual challenges to Plaintiffs’ standing to sue. II. LEGAL STANDARDS Rule 12(b)(1). “Federal courts are courts of limited jurisdiction.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375, 377 (1994).

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The Haitian Diaspora Political Action Committee, et al. v. The American Red Cross, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-haitian-diaspora-political-action-committee-et-al-v-the-american-red-flsd-2025.