Zang v. Bank of America Corporation
- Subramanian
- 1:25-cv-06224
- U.S. District Court · Southern District of New York
- 2
In Zang v. Bank of America Corporation, Judge Subramanian dismissed the federal claim and granted remand, sending the case back to state court.
Zi Xiu Zang and Bank of America Corporation; the federal case was closed after the FCBA claim was dismissed and the motion to remand was granted.
What happened
Zi Xiu Zang sued Bank of America Corporation in New York state court. Bank of America removed the case to federal court, citing a federal Fair Credit Billing Act claim. Zang, representing themself, asked the federal court to send the case back.
Zang argued that the claims were based only on New York law and that the complaint’s reference to federal law did not create federal jurisdiction. The court treated the request to remand as a withdrawal of the federal claim.
The court dismissed the Fair Credit Billing Act claim, granted the motion to remand, directed the clerk to terminate the motion, and closed the case. Judge Arun Subramanian issued the order.
The detailed version
- Zang v. Bank of America Corporation · No. 1:25-cv-06224
- Subramanian
- Aug. 20, 2025
Background
Zi Xiu Zang filed the case in the Civil Court of the City of New York on June 20, 2025. Bank of America Corporation removed it to the Southern District of New York on July 29, 2025, asserting federal-question jurisdiction based on an alleged claim under the Fair Credit Billing Act (FCBA).
The state-court complaint alleged that Bank of America’s conduct violated both the FCBA and New York General Business Law § 520-e. Zang moved to remand the case to state court and argued that the claims were brought solely under New York law. Zang also argued that the amount in controversy was $8,621.62 and that diversity jurisdiction was unavailable.
Ruling
The court construed Zang’s motion to remand as a withdrawal of the federal claim. It therefore dismissed the FCBA claim and granted the motion to remand. The court directed the clerk to terminate the motion at ECF No. 10 and close the case. The order does not provide a separate merits decision on the New York-law claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.