Alexander v. JP Morgan Chase Bank, N.A.

Background

Jeriel Alexander alleged that he went to a Chase branch to withdraw $3,330 from his checking account. According to the amended complaint, a teller requested multiple forms of identification, delayed the transaction, and said she had to run a criminal background check before completing the withdrawal. Alexander alleged that the teller then said she would not process the withdrawal because he was Black. After Alexander spoke with a branch manager, identified as “Mr. Robert,” he received the money.

Alexander also alleged that he called Chase’s customer service line to report racial discrimination and that Chase did not investigate or discipline the teller. He further alleged that Chase later deposited $116 into his account as a bribe, disguising the deposit as a reversal of overdraft fees. The opinion notes that the Bank Bribery Act does not provide a private right of action for an alleged violation.

Legal standard

Chase moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to state a legally plausible claim. The court was required to treat the complaint’s factual allegations as true and interpret the submissions of the self-represented plaintiff to raise the strongest arguments they suggested. Even so, Alexander had to allege sufficient facts to support a plausible claim.

Federal claims

The court had previously dismissed Alexander’s Title II claim and had not allowed him to amend that claim. The court explained that a bank is not a place of public accommodation under Title II. It also noted that Title II does not allow damages and that a plaintiff seeking an injunction must show a real and imminent threat of repeated injury. Because Alexander reasserted the Title II claim, the court dismissed it again.

The court had allowed Alexander to amend a claim under 42 U.S.C. § 1981, a federal law protecting the right to make and enforce contracts without racial discrimination. Although the amended complaint did not cite Section 1981, the court construed it as asserting that claim.

The court concluded that Alexander did not allege facts satisfying the required part of a Section 1981 claim. He received the money he sought to withdraw, so the bank’s contract with him was completed. His allegations of a twenty-minute delay and requests for identification did not show that he was prevented from completing the transaction or required to complete it on different terms from nonminority customers. The court found his assertion that he was denied equal treatment conclusory and dismissed the Section 1981 claim. Because Alexander had already amended his complaint and the court found no indication that another amendment would state a valid claim, it determined that further amendment would be futile.

State-law claims and disposition

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over the state-law claims. The court dismissed those claims without prejudice to filing them in state court.

Judge Ona T. Wang granted Chase’s motion to dismiss. Alexander’s federal claims under Title II and Section 1981 were dismissed with prejudice. His state-law claims were dismissed without prejudice to filing them in state court. The clerk was directed to close the motion and mail Alexander a copy of the opinion.