Jalalian v. JPMorgan Chase Bank, N.A.

Background

Armen Jalalian, proceeding without a lawyer, sued JPMorgan Chase Bank, N.A. and Marianne Lake over the alleged wrongful retention and sale of his car. Jalalian alleged that he bought a Subaru Forester in July 2024 with financing from Chase. Chase repossessed the car in November 2024 for nonpayment. According to the First Amended Complaint, a Chase employee told Jalalian that the car would be released if he paid $4,485.37. Jalalian alleged that he sent that amount by wire transfer on December 23, 2024, and that another Chase employee confirmed receiving it.

Jalalian alleged that Chase later said it had not received the money because his bank used the wrong SWIFT code. Chase stated that $5,183.48 remained due to reinstate the car before its sale. Jalalian alleged that his bank had used the correct code, but Chase refused to change its position. Chase sold the car on March 4, 2025, and demanded that Jalalian pay $16,728.32 as the remaining balance. He alleged financial costs, missed medical appointments, and emotional distress.

Jalalian asserted claims against Chase for breach of contract, fraudulent and negligent misrepresentation, conversion, constructive trust, breach of the covenant of good faith and fair dealing, and unfair business practices. The opinion states that he asserted claims against Chase; it does not identify separate substantive claims against Lake.

Motions and Jurisdiction

Chase and Lake each moved to dismiss the First Amended Complaint. Lake argued that the court lacked subject-matter jurisdiction and personal jurisdiction, that she had not been properly served, and that the complaint did not allege facts or claims against her. Chase also argued that the court lacked subject-matter jurisdiction and that the complaint failed to state a claim.

Jalalian invoked diversity jurisdiction under 28 U.S.C. § 1332(a), alleging that more than $75,000 was in dispute. He alleged that he was a citizen of California and that Chase was a national banking association with its main office in New York, New York, and therefore a citizen of New York for diversity purposes. He did not allege Marianne Lake’s citizenship.

Diversity jurisdiction requires complete diversity, meaning that every plaintiff must be a citizen of a different state from every defendant. The court held that Jalalian had the burden to plead and prove diversity jurisdiction. Because he did not allege Lake’s citizenship, he failed to plead complete diversity. The court also stated that no basis for federal-question jurisdiction existed.

Disposition

The court granted Defendants Chase and Lake’s motions to dismiss based on lack of subject-matter jurisdiction. It dismissed the First Amended Complaint without prejudice, meaning the dismissal did not bar Jalalian from attempting to correct the jurisdictional allegations. The court allowed him to file a Second Amended Complaint by June 20, 2025, if he chose to do so.

Because the court found that the First Amended Complaint did not establish subject-matter jurisdiction, it did not consider the defendants’ other arguments. Judge Lisa J. Cisneros entered the order as a United States Magistrate Judge.