CLARK v. SOFI
2:25-cv-00909
E.D. Pa.Jun 4, 2025Background
- Joy Lucretia Clark, proceeding pro se, filed a civil action against SoFi Bank and OneMain Financial after being denied personal loans by both entities.
- Clark alleged that SoFi’s denial letter stated credit reporting agencies did not factor in the credit decision and that SoFi could not provide specific reasons for denying her application.
- Clark expressed suspicion about how her social security number and signature were used, speculating (without factual support) that SoFi may have created a security instrument with her information.
- She cited several statutes (National Currency Act, Federal Deposit Insurance Act, Truth in Lending Act (TILA), Equal Credit Opportunity Act, "state usury laws") as supposed grounds for relief.
- Clark sought damages for affected credit, hardship, pain, and suffering, and asked for the “security” created from her information to be returned.
- The court granted in forma pauperis status but screened the complaint for frivolousness and failure to state a claim under 28 U.S.C. § 1915(e)(2)(B).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Claim against OneMain for denial of loan | OneMain denied her application, referenced in exhibits | No facts/claims pled against OneMain | Dismissed—complaint devoid of factual or legal claims |
| Violation of National Currency Act/Federal Deposit Insurance Act | Clark asserted these statutes regulate lending and SoFi's actions violated them | Not argued | Dismissed—no private right of action/legal basis |
| TILA Violation | SoFi failed to disclose loan terms or created a security with her information | Not argued | Dismissed—no loan was made, so TILA not applicable |
| Equal Credit Opportunity Act Violation | Denial raises concern about improper use of her SSN and possible discrimination | Not argued | Dismissed—no facts supporting discrimination |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (1989) (standard for frivolousness for IFP complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for plausibility under Rule 12)
- Deutsch v. United States, 67 F.3d 1080 (3d Cir. 1995) (defining legally baseless/frivolous claims)
- Touche Ross & Co. v. Redington, 442 U.S. 560 (1979) (private right of action test for federal statutes)