Williams v. Citibank, N.A.
James Williams, a pro se plaintiff, filed claims against Citibank N.A. and Citibank (South Dakota) N.A., alleging unlawful debt collection practices under the Fair Debt Collection Practices Act (FDCPA), breach of contract, and fraud. The claims stemmed from actions related to two credit card accounts, where Plaintiff contended an inadvertent 50-cent underpayment led to a significant APR increase and aggressive collection efforts. Defendants moved to dismiss all claims except for breach of contract. The Court dismissed the federal FDCPA claim, ruling that the Citibank entities were creditors and not 'debt collectors' as defined by the FDCPA. Plaintiff was granted leave to amend his complaint to attempt to establish the applicability of the FDCPA’s 'false name exception'. The remaining state law claims were dismissed without prejudice, with potential reconsideration if a viable FDCPA claim is presented.