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Guridy v. American Express Company
1:24-cv-02251
N.D. Ohio
Jun 4, 2025
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Background

  • 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)
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Case Details

Case Name: Guridy v. American Express Company
Court Name: District Court, N.D. Ohio
Date Published: Jun 4, 2025
Docket Number: 1:24-cv-02251
Court Abbreviation: N.D. Ohio