E.J. Chin Realty Corp. v. JPMorgan Chase Bank, N.A.
- Alvin Hellerstein
- 1:23-cv-04485
- U.S. District Court · Southern District of New York
- 3
In E.J. Chin Realty Corp. v. JPMorgan Chase Bank, Judge Hellerstein granted J.P. Morgan Chase & Co.’s motion to dismiss.
E.J. Chin Realty Corp., Eddy Chin, and Siu Chee Chin; J.P. Morgan Chase & Co., which was dismissed from the action; and JPMorgan Chase Bank, N.A., which remained as a defendant subject to the amended pleading and jurisdictional requirements.
What happened
E.J. Chin Realty Corp. v. JPMorgan Chase Bank, N.A. involves negligence and contract claims by E.J. Chin Realty Corp., Eddy Chin, and Siu Chee Chin concerning assets stored in a safe-deposit box. The plaintiffs sued JPMorgan Chase Bank, N.A. and J.P. Morgan Chase & Co., which removed the case from state court to federal court.
J.P. Morgan Chase & Co. asked the court to dismiss the claims against it. The court said the complaint contained no facts connecting that company to the alleged wrongdoing and that being the bank’s corporate parent and holding company was not enough by itself to create liability.
Judge Hellerstein granted J.P. Morgan Chase & Co.’s motion and dismissed the complaint against that company. The plaintiffs were ordered to file an amended complaint dropping J.P. Morgan Chase & Co.; the case continued against JPMorgan Chase Bank, N.A., subject to the court’s stated jurisdictional and pleading requirements.
The detailed version
- E.J. Chin Realty Corp. v. JPMorgan Chase Bank, N.A. · No. 1:23-cv-04485
- Alvin Hellerstein
- Jan. 22, 2024
Background
E.J. Chin Realty Corp., Eddy Chin, and Siu Chee Chin filed the action in New York state court on April 24, 2023. They asserted negligence and breach-of-contract claims against JPMorgan Chase Bank, N.A. and J.P. Morgan Chase & Co., alleging that the defendants failed to safely guard the plaintiffs’ assets stored in a safe-deposit box on the Upper East Side. The defendants removed the action to federal court on May 30, 2023. JPMorgan Chase Bank, N.A. filed an answer, and J.P. Morgan Chase & Co. moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which permits dismissal when a complaint does not adequately state a legal claim.
Court’s Analysis
The court held that the complaint contained no facts associating J.P. Morgan Chase & Co. with the alleged wrongdoing. The opinion identified J.P. Morgan Chase & Co. as the corporate parent and holding company of JPMorgan Chase Bank, N.A. It explained that this status alone could not support liability for the alleged conduct. The court therefore dismissed the complaint against J.P. Morgan Chase & Co.
The court stated that it continued to have subject-matter jurisdiction under 28 U.S.C. § 1332. It identified the plaintiffs as New York citizens and JPMorgan Chase Bank, N.A. as a federally chartered bank with its principal place of business in Ohio.
Disposition
Judge Alvin K. Hellerstein granted J.P. Morgan Chase & Co.’s motion to dismiss. The plaintiffs were ordered to file an amended complaint by January 31, 2024, dropping J.P. Morgan Chase & Co. The amended complaint also had to allege the parties’ citizenship and facts plausibly showing more than $75,000 in lost or damaged property, excluding interest and costs. The court set deadlines for initial disclosures, a proposed case-management plan, and joint appearances, and scheduled an initial case-management conference for February 23, 2024. The Clerk was instructed to terminate the open motion at ECF No. 11.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.