Guridy v. American Express Company
1:24-cv-02251
N.D. OhioJun 4, 2025Background
- Plaintiff, Leidy V. Guridy, applied online for an American Express platinum rewards credit card in December 2023.
- Guridy voluntarily offered an unspecified security interest as part of the application process.
- American Express denied her application for reasons not disclosed to Guridy.
- Guridy, proceeding pro se, alleged breach of contract, federal securities law violations, and unjust enrichment.
- She sought issuance of the credit card, monetary damages, and other compensation.
- The court granted Guridy's motion to proceed in forma pauperis due to her limited income but reviewed her complaint for legal sufficiency before service.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Breach of contract | Amex breached by not providing the credit card or compensation for her security interest | No valid contract existed | No plausible contract or breach alleged; claim dismissed |
| Violation of federal securities | Amex securitized/traded her application without consent or compensation | Allegations are conclusory | Allegations insufficient; claim dismissed |
| Unjust enrichment | Amex profited from her offered security interest without compensation | Unclear/unsupported assertions | Allegations fail basic pleading standards; claim dismissed |
| In forma pauperis status | Inability to pay filing fee confirmed by low income | N/A | Motion granted, but case dismissed under initial review |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (articulates standards for complaint plausibility)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (requires complaints to state a plausible claim)
- Swierkiewicz v. Sorema N.A., 534 U.S. 506 (2002) (complaints must provide fair notice of claims)
- Boag v. MacDougall, 454 U.S. 364 (1982) (pro se complaints are held to less stringent standards)
- Haines v. Kerner, 404 U.S. 519 (1972) (liberal construction given to pro se pleadings)
