Varlack v. Bank of America

CourtDistrict Court, S.D. New York
DecidedOctober 16, 2023
Docket1:23-cv-06270
StatusUnknown

This text of Varlack v. Bank of America (Varlack v. Bank of America) 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
Varlack v. Bank of America, (S.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK TYNEARIA A, VARLACK, Plaintiff, 23-CV-6270 (LTS) -against- ORDER TO AMEND BANK OF AMERICA; EARLY WARNING SYSTEMS; CHEX SYSTEMS, Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Plaintiff Tynearia A. Varlack, of Bronx County, New York, filed this pro se action. She sues Bank of America, Early Warning Systems, and Chex Systems, alleging that Defendants violated her rights. By order dated July 31, 2023, the Court granted Plaintiff’s request to proceed without prepayment of fees, that is, in forma pauperis (“IFP”). For the reasons set forth below, the Court grants Plaintiff leave to file an amended complaint within 60 days of the date of this order. 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. 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. 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 Plaintiff brings this action using the Court’s general complaint form, invoking the Court’s federal question jurisdiction. In the section that asks Plaintiff which of her federal constitutional or federal statutory rights have been violated, Plaintiff writes, “UCC 1-308[,] US code 1681b[,] US code 1681.” (ECF No. 2 at 2.) In her statement of claim, Plaintiff alleges the following: On 9-19-2018 there was a fraudulent account openend under my name without my consent and it has been reporting on my consumer report for 6 years now which is illegal, the banking system is dependent upon fair and accurate credit reporting. In accurate credit reports directly impairs the efficiency of the banking system & unfair credit reporting methods undermine the public confidence which is essential to continued functioning of the banking system. Now well if a negative account is on my consumer report & I can’t use my consumer report in regards to that negative account how is the fair under the FCRA, how is it fair to me if I can’t use my credit report. (Id. at 5.)1 Plaintiff alleges that her injuries include “loss of credit, mental anxiety, deformation of character, I see a pschy.” (Id. at 6.) By way of relief, Plaintiff states that she “want[s] the highest amount 7,000,000,000 for my damages.” (Id.) DISCUSSION The Court construes Plaintiff’s allegations as asserting claims under the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. § 1681 et seq., based upon Plaintiff’s citing federal statutes that govern accessing credit information and her allegations that Defendants violated her rights. A. FCRA Congress enacted the FCRA to ensure that “consumer reporting agencies adopt reasonable procedures for meeting the needs of commerce for consumer credit, personnel, insurance, and other information in a manner which is fair and equitable to the consumer, with regard to the

1 The Court quotes the complaint verbatim. All spelling, punctuation, and grammar are as in the original. confidentiality, accuracy, relevancy, and proper utilization of such information.” 15 U.S.C. § 1681(b). The FCRA regulates the activities of consumer reporting agencies and the use and dissemination of consumer credit information. See 15 U.S.C.

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Bluebook (online)
Varlack v. Bank of America, Counsel Stack Legal Research, https://law.counselstack.com/opinion/varlack-v-bank-of-america-nysd-2023.