Taylor v. Enterprise Holding Group, LLC

Background

Ronald G. Taylor proceeded without a lawyer and sought to proceed without paying filing fees. He alleged that, in 2019, he rented a Jeep Grand Cherokee through Enterprise. Enterprise blamed him for damage to the vehicle, although Taylor said he was not involved in the incident. According to Taylor, an Enterprise employee relied on information from a garage attendant and concluded that Taylor had caused the damage.

Taylor alleged that Enterprise failed to address his assertion that it was accepting the word of a white man over that of Taylor, who is Black. He also alleged that Enterprise demanded $1,000 to settle the claim or it would end its business relationship with him, which Taylor said would interfere with his ability to rent cars from other companies. Taylor further alleged that he was not allowed to conduct his own investigation.

Taylor originally asserted claims under the Fair Debt Collection Practices Act, a federal law regulating certain debt-collection conduct; 18 U.S.C. § 875(d), a federal criminal statute concerning extortion; and 22 U.S.C. § 2755, which concerns racial discrimination in furnishing defense articles or defense services. The court also interpreted the original complaint as asserting a claim under 42 U.S.C. § 1981, a federal civil-rights statute protecting certain contracting rights.

Earlier Order and Amended Complaint

In an order dated September 18, 2020, the court concluded that the original complaint failed to state a claim. It ruled that Enterprise was not a debt collector under the Fair Debt Collection Practices Act because it was seeking to collect a debt on its own behalf. It also ruled that Taylor could not bring a claim under the federal criminal extortion statute and that his allegations did not support a claim under 22 U.S.C. § 2755.

The court further concluded that Enterprise’s failure to disavow Taylor’s assertion of race discrimination, without more, did not state a viable claim under § 1981. The court also considered possible state-law claims based on diversity jurisdiction, which allows a federal court to hear certain disputes between parties from different states. It found that the complaint did not allege the members’ domiciles of the limited liability company and did not provide facts showing a reasonable probability that more than $75,000 was at stake. The court gave Taylor an opportunity to amend.

Taylor filed an amended complaint on November 4, 2020. He again relied solely on federal-question jurisdiction, asserted a Fair Debt Collection Practices Act harassment claim and a § 1981 discrimination claim, and sought $100,000 in punitive damages. The amended complaint did not add facts supporting those federal claims, did not expressly assert diversity jurisdiction or state-law claims, and did not provide facts about the parties’ domiciles. The court noted that the amended complaint listed an address for Enterprise’s registered agent in Jericho, New York, but found that this did not supply the missing jurisdictional facts.

Ruling

The court dismissed the amended complaint for the same reasons stated in the September 18 order. It concluded that the amended complaint added no facts establishing a claim under the Fair Debt Collection Practices Act, § 1981, or any other federal law.

Because the federal claims were dismissed, the court declined to exercise supplemental jurisdiction—the court’s discretionary authority to hear related state-law claims—over any state-law claims Taylor might have been asserting. The court also declined to give Taylor another opportunity to amend because he had already amended once and the amended complaint gave no indication that the defects could be cured.

The Clerk of Court was directed to mail the order to Taylor and record service on the docket. Judge Louis L. Stanton dismissed the amended complaint for failure to state a claim under 28 U.S.C. § 1915(e)(2)(B)(ii). The order did not state that the dismissal was with or without prejudice.