Thomas v. JPMorgan Chase Bank N.A.
- Rearden
- 1:21-cv-08477
- U.S. District Court · Southern District of New York
- 4
In Thomas v. JPMorgan Chase Bank N.A., Judge Rearden adopted the recommendation, granted Chase’s summary judgment, and denied Thomas’s motion.
Arnold H. Thomas and JPMorgan Chase Bank N.A.; the ruling favors Chase by granting its summary-judgment motion and denying Thomas’s.
What happened
In Thomas v. JPMorgan Chase Bank N.A., Arnold H. Thomas sued the bank, alleging that it failed to disclose important facts related to issuing him a credit card. His claims included allegations under federal credit and disclosure laws, while Chase asserted its own claims for breach of contract and an unpaid account.
The parties filed competing requests for summary judgment, which asks the court to rule when no important factual dispute requires a trial. A magistrate judge recommended granting Chase’s request and denying Thomas’s request, finding no genuine dispute about Thomas’s claims or Chase’s claims. Thomas did not object to that recommendation.
Judge Rearden found no clear error, adopted the recommendation in full, granted Chase’s motion for summary judgment, and denied Thomas’s motion for summary judgment. The court directed Chase to submit a proposed judgment by June 25, 2025.
The detailed version
- Thomas v. JPMorgan Chase Bank N.A. · No. 1:21-cv-08477
- Rearden
- June 16, 2025
Background
Arnold H. Thomas, representing himself, sued JPMorgan Chase Bank N.A. Thomas alleged that Chase failed to disclose important facts connected to the issuance of a credit card. The opinion broadly construed his complaint as asserting claims under the Truth in Lending Act, Regulation Z, the Fair Credit Reporting Act, the Credit Card Accountability and Responsibility and Disclosure Act, and 12 U.S.C. § 1831.
Chase answered and asserted counterclaims for breach of contract and account stated. After fact discovery closed, the parties filed competing motions for summary judgment under Rule 56. A summary-judgment motion asks the court to decide a claim without a trial when there is no genuine dispute about a fact that could affect the outcome.
Report and Recommendation
Magistrate Judge Sarah L. Cave recommended denying Thomas’s motion for summary judgment and granting Chase’s motion. The recommendation stated that there was no genuine issue of material fact concerning Thomas’s claims or Chase’s counterclaims. The parties were given fourteen days to object, and the recommendation warned that failing to object would waive objections and prevent appellate review. No objections or request for more time were filed.
Because there were no timely objections, the district court reviewed the recommendation for clear error rather than conducting a new review of the disputed issues. The court stated that it nevertheless carefully reviewed the recommendation and found it well supported by the facts and law.
Ruling
Judge Jennifer H. Rearden adopted the Report and Recommendation in its entirety. The court granted Chase’s motion for summary judgment and denied Thomas’s motion for summary judgment. The court directed Chase to file a proposed judgment by June 25, 2025, and directed the clerk to terminate the two summary-judgment motions and mail Thomas a copy of the order.
The order does not independently set out the detailed factual and legal reasoning underlying the recommendation; it adopts that recommendation after finding no clear error.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.