Boyd v. PNC Bank Financial Service Group Inc
2:25-cv-00569
| E.D. Wis. | Apr 29, 2025Background
- Joy Boyd, proceeding pro se, sued PNC Bank in the Eastern District of Wisconsin, alleging breach of contract and breach of fiduciary duty after PNC denied her application for a $75,000 personal loan.
- Boyd filed a motion for leave to proceed in forma pauperis (IFP) without paying the filing fee, but failed to provide required financial information.
- The court reviewed both Boyd’s IFP motion and the sufficiency of her complaint (screening under 28 U.S.C. § 1915).
- Boyd’s complaint was based solely on state-law claims but asserted federal question jurisdiction; the parties were not diverse, defeating diversity jurisdiction.
- The court also found the amount in controversy to be insufficient for diversity jurisdiction and that the facts alleged could not support a plausible contract or fiduciary relationship.
- Judge Ludwig dismissed Boyd's case without leave to amend, finding the claims legally frivolous and amendment futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| IFP Motion | She is unable to pay the filing fee | Plaintiff failed to show indigency | IFP denied—insufficient financial disclosure |
| Subject Matter Jurisdiction | Federal question jurisdiction | No federal question; no diversity | No federal jurisdiction—state law claims, no diversity or amount |
| Sufficiency of Claims | Loan denial created contract/fiduciary duties | No contract or duty formed | No plausible claim; claims are legally frivolous |
| Leave to Amend | Should be permitted | Amendment would be futile | Denied due to futility |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (explaining the pleading standard under Rule 8 and plausibility requirement)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (setting forth standards for pleading factual content and plausibility)
- Luevano v. Wal-Mart Stores, Inc., 722 F.3d 1014 (7th Cir. 2013) (discussing screening and dismissal of pro se complaints)
- Felton v. City of Chicago, 827 F.3d 632 (7th Cir. 2016) (defining legal frivolousness in civil complaints)
- Williams v. Faulkner, 837 F.2d 304 (7th Cir. 1988) (defining a frivolous complaint as lacking rational legal or factual basis)