Robert Wallace-Bey v. America's Christian Credit Union

Summary

The Eastern District of New York dismissed Robert Wallace-Bey’s second amended complaint against America’s Christian Credit Union without prejudice. The court held that Plaintiff lacked standing because the denied membership application belonged to Temple of Seven Inc., and alternatively held that the allegations did not state a claim under the Equal Credit Opportunity Act.

Holdings

1. Plaintiff lacked Article III standing because he did not allege that he personally was denied a ministry account and could not assert the corporation's injury.
2. Plaintiff failed to state an Equal Credit Opportunity Act claim because he did not allege facts suggesting that the denial was based on race, color, religion, national origin, sex, marital status, or age.

Questions Presented

1. Whether Plaintiff had Article III standing to challenge the denial of an account application made by or for Temple of Seven Inc.
2. Whether Plaintiff stated an Equal Credit Opportunity Act claim by alleging that the account application was denied based on a personal credit-history charge-off rather than a protected characteristic.

Disposition

dismissed