Lensendro v. Young
3:24-cv-01760
D. Conn.Apr 14, 2025Background
- Pro se plaintiff Laguerre Lensendro filed a two-count complaint against Capital One Financial Corporation, its CFO Andrew M. Young, and an unnamed surety.
- Lensendro alleges he was denied credit by Capital One due to insufficient income after applying for multiple credit cards online.
- He claims violations of the Equal Credit Opportunity Act (ECOA) for discriminatory denial and the Truth in Lending Act (TILA) for failure to disclose credit terms.
- Defendants moved to dismiss, arguing the plaintiff failed to adequately plead essential elements of either claim.
- The court addresses the sufficiency of the ECOA and TILA claims, not reaching issues of proper defendant status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ECOA: Discrimination by Denial on Income | Denied credit based on income violated ECOA | Denial was based on permissible assessment of creditworthiness | ECOA claim dismissed; no discrimination |
| ECOA: Membership in Protected Class | Implied discrimination by denial for income | No allegation of discrimination on protected basis | No protected class alleged; dismissed |
| TILA: Duty to Disclose at Pre-Approval | Was denied loan info needed to make informed choices | Disclosure obligations arise only if credit is actually extended | No credit extended; TILA claim dismissed |
| Proper Party (Are Defendants “Creditors”) | Defendants are responsible under both laws | Holding company and individuals not creditors for liability | Not necessary to reach; dismissed on other grounds |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading standard for Rule 12(b)(6) motions)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for complaints)
- Strubel v. Comenity Bank, 842 F.3d 181 (TILA disclosures apply when credit is extended, not at pre-approval)
- Vincent v. The Money Store, 736 F.3d 88 (ECOA and TILA require defendant to be a statutory creditor)