Thomas v. JPMorgan Chase Bank N.A.
1:21-cv-08477
S.D.N.Y.Jun 16, 2025Background
- Arnold H. Thomas, proceeding pro se, sued JPMorgan Chase Bank ("Chase") alleging nondisclosure of material facts related to a credit card issuance.
- Plaintiff asserted claims under several consumer protection statutes, including the Truth in Lending Act and the Fair Credit Reporting Act.
- Chase responded with counterclaims for breach of contract and account stated.
- Both parties filed cross-motions for summary judgment after discovery closed.
- Magistrate Judge Sarah L. Cave recommended granting summary judgment in favor of Chase and denying Thomas’s cross-motion, finding no genuine issues of material fact.
- Thomas did not file objections to the Report and Recommendation, and the District Court adopted it in full, granting judgment to Chase.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disclosure of material facts | Chase failed to disclose key credit card facts | All disclosures complied with legal duties | Court found no disclosure failure |
| Truth in Lending Act violations | Violations of statutes governing credit issuance | Complied with all lending regulations | No violations found by the court |
| Breach of contract (counterclaim) | - | Thomas failed to meet card agreement terms | Summary judgment for Chase |
| Account stated (counterclaim) | - | Thomas did not dispute the card account | Summary judgment for Chase |
Key Cases Cited
- United States v. U.S. Gypsum Co., 333 U.S. 364 (definition of clear error in reviewing magistrate reports)
- Thomas v. Arn, 474 U.S. 140 (party's failure to object to magistrate’s report waives appellate review)
- Easley v. Cromartie, 532 U.S. 234 (clear error standard for district review of magistrate decisions)
- Frank v. Johnson, 968 F.2d 298 (failure to object constitutes waiver of further review)
- Mario v. P & C Food Markets, Inc., 313 F.3d 758 (failure to timely object forfeits further judicial review)