Rogers v. Citi Bank
- Laura Swain
- 1:25-cv-02342
- U.S. District Court · Southern District of New York
- 4
In Rogers v. Citi Bank, Judge Stanton dismissed Joshua Rogers’s complaint for inadequate allegations and declined to allow amendment.
Joshua Rogers’s case was dismissed, and he was not given permission to amend the complaint. Citi Bank and Loretta Elizabeth Lynch were no longer required to respond to this complaint after dismissal. The court’s prior warning concerning Rogers’s future fee-waived filings remained in effect.
What happened
In Rogers v. Citi Bank, Joshua Rogers, representing himself and filing without paying the filing fee, sued Citibank and Loretta Elizabeth Lynch. He alleged that a chief executive opened an account for him that he could not access, and he sought $80 million for alleged quality-of-life injuries.
The court said the complaint did not give the defendants fair notice of the claims or explain their legal basis. It also did not explain why the federal court had authority to hear the case. The court therefore found that the complaint failed to state a claim under the required pleading rules.
Judge Louis L. Stanton dismissed the complaint, declined to grant Rogers permission to amend it, and directed the clerk to enter judgment dismissing the case. The court also left in place an earlier warning that Rogers might be required to obtain permission before filing future complaints without paying fees in that court.
The detailed version
- Rogers v. Citi Bank · No. 1:25-cv-02342
- Laura Swain
- July 31, 2025
Background
Joshua Rogers, proceeding without a lawyer, filed the action without stating whether he relied on federal-question jurisdiction or diversity jurisdiction. He asserted a breach-of-contract claim against Citi Bank and Loretta Elizabeth Lynch. Rogers alleged that on February 19, 2025, the “CEO opened an account for” him and that he could not access or retrieve money. He sought $80 million for “quality of life” injuries.
The court had previously allowed Rogers to proceed without paying filing fees. Because the action was filed without payment of fees, the court reviewed the complaint under 28 U.S.C. § 1915. That law requires dismissal of such a complaint if it is frivolous, malicious, fails to state a claim, or seeks money from a defendant protected from that relief. The court also noted that it must dismiss claims when it lacks authority to hear them.
Court’s Analysis
The court explained that Federal Rule of Civil Procedure 8 requires a complaint to provide a short and plain statement showing that the plaintiff is entitled to relief. The allegations must contain enough factual detail to make liability plausible and must give each defendant fair notice of the claim and its basis. Although courts interpret complaints filed by people without lawyers generously, those complaints still must satisfy the basic pleading rules.
The court found that Rogers’s “barebones” allegations did not identify the legal basis of his claims, give the defendants fair notice of what they allegedly did wrong, or explain why the federal court had jurisdiction. The court therefore concluded that the complaint failed to state a claim and dismissed it under 28 U.S.C. § 1915(e)(2)(B)(ii).
Disposition
The court dismissed Rogers’s complaint. It declined to grant leave to amend because it concluded that the defects could not be cured by amendment. The court directed the clerk to enter judgment dismissing the case.
The court also stated that Rogers had filed more than eleven cases without a lawyer in the district during 2024 and 2025. It left in effect an earlier warning that, if Rogers continued to abuse the privilege of proceeding without paying filing fees, the court could require him to show why he should not be barred from filing future complaints without paying fees unless he first obtained the court’s permission.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.