Swanson v. Citibank, N.A.

Brief Fact Summary.

Swanson filed a pro se discrimination action against Citibank and others in connection with her application for a home equity loan. The district court dismissed the complaint, which had included a claim for violations of the federal Fair Housing Act and what the court had construed as a common law fraud claim. Swanson appealed.

Synopsis of Rule of Law.

A plaintiff must plead sufficient details to present a “story that holds together”; the court will consider whether the allegations as stated could have happened.

Facts.

Swanson, proceeding pro se, filed acomplaint against Citibank and others in connection with her application for a home equity loan. Swanson alleged that the defendants had discriminated against her based on her race in rejecting her loan application.  She asserted, among other things, a claim for violations of the federal Fair Housing Act, which the district court dismissed. The district court also construed Swanson’s complaint liberally to include a fraud claim, but that claim was ultimately dismissed as well. Swanson appealed.

Issue.

Were the claims asserted by Swanson in her complaint properly dismissed?

Held.

Yes and no. The Court of Appeals reversed the district court’s judgment as to the Fair Housing Act claims, and affirmed the district court’s judgment as to the common law fraud claims.

Dissent.

Justice Posner

The dissent argued against reversal of the dismissal of the housing discrimination claim because, based on the allegations of the complaint, the claim was implausible.

Discussion.

A plaintiff must plead sufficient details to present a “story that holds together.” In a straightforward case, few details may be necessary, while more detail will be required in a more complex proceeding.