Young Groeneweg v. Citibank NA — Federal Court Retains Jurisdiction Over FDCPA Claims
Summary
Pro se plaintiff Young Groeneweg filed a motion to remand her Fair Debt Collection Practices Act suit against Citibank NA back to Indiana state court, arguing that the parallel debt collection action pending in Allen Superior Court warranted consolidation in one forum. The US District Court for the Northern District of Indiana denied the remand motion on April 7, 2026, holding that original federal question jurisdiction over the FDCPA claim under 28 U.S.C. § 1331 is proper regardless of the amount in controversy. The court further exercised supplemental jurisdiction over the state law claims (conversion, unjust enrichment, invasion of privacy, and intentional infliction of emotional distress), finding no exception under 28 U.S.C. § 1367(c) applied — specifically, the state claims do not substantially predominate over the single federal claim since all claims derive from the same nucleus of operative facts.
“The FDCPA is a federal cause of action, meaning this Court has original jurisdiction over that claim.”
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GovPing monitors US District Court NDIN Docket Feed for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 16 changes logged to date.
What changed
The court denied plaintiff Young Groeneweg's motion to remand case number 1:26-cv-00074 to Allen Superior Court. The court held that because the FDCPA is a federal statute creating a federal cause of action, 28 U.S.C. § 1331 gives this Court original jurisdiction regardless of the amount in controversy — removal based on federal question jurisdiction contains no controversy requirement. The court further held that supplemental jurisdiction under 28 U.S.C. § 1367(a) extends to all state law claims (conversion, unjust enrichment, invasion of privacy, and intentional infliction of emotional distress) because they share the same nucleus of operative facts as the FDCPA claim. No exception under 28 U.S.C. § 1367(c) applied — state claims do not substantially predominate since all claims focus on the same conduct by Citibank and would require largely overlapping evidence. The pendency of parallel state court collection actions did not bar federal jurisdiction under McClellan v. Carland.
For defendants in consumer debt collection matters, this ruling reinforces that a single federal cause of action (such as an FDCPA counterclaim) creates a jurisdictional gateway through which federal courts may adjudicate accompanying state law claims, even where the plaintiff sought to keep the case in state court. Entities engaged in debt collection litigation should anticipate that federal courts exercising federal question jurisdiction will generally retain related state claims unless a compelling exception under § 1367(c) exists.
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Apr 26, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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April 7, 2026 Get Citation Alerts Download PDF Add Note
Young Groeneweg v. Citibank NA
District Court, N.D. Indiana
- Citations: None known
- Docket Number: 1:26-cv-00074
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA
FORT WAYNE DIVISION
YOUNG GROENEWEG,
Plaintiff,
v. CASE NO. 1:26-CV-74-HAB-ALT
CITIBANK NA,
Defendant.
OPINION AND ORDER
Pro se Plaintiff Young Groeneweg (“Groeneweg”) filed a complaint on January 21, 2026,
against Defendant Citibank NA (“Citibank”) alleging unlawful debt collection practices under the
Fair Debt Collection Practices Act, 15 U.S.C. § 1692, and Indiana state law claims allegedly
arising from those practices. (ECF No. 4). Citibank first pursued a civil debt collection against
Groeneweg in state court. (Id.) Groeneweg then filed her own claims against Citibank in a separate
suit and moved to consolidate the actions, which the state court granted.1 (Id.) On February 9,
2026, Citibank removed Groeneweg’s FDCPA suit to federal court, alleging federal question
jurisdiction. (ECF No. 1). Groeneweg now asks the Court to remand the case to the state court,
(ECF No. 5), and the motion is fully briefed and ripe for ruling. (ECF No. 5, 11, 12).
Federal district courts “have original jurisdiction of all civil actions arising under the
Constitution, laws, or treaties of the United States.” 28 U.S.C. § 1331. If a plaintiff brings a civil
action in state court that federal courts have original jurisdiction over, the defendant or defendants
1 Under Rule 201 of the Federal Rule of Evidence, the Corut takes judicial notice of the state court dockets in the
two cases, consolidated on February 2, 2026. See Citibank NA v. Young Groeneweg, Cause No. 02D02-2601-SC-
000069 (debt collection suit); Young Groeneweg v. Citibank NA, No. 02D03-2601-PL-000017 (Groeneweg’s
countersuit alleging claims under the FDCPA and Indiana common law).
may remove the case to the district court where the action is pending. 28 U.S.C. § 1441. District
courts can also exercise supplemental jurisdiction over state-law claims that accompany federal
claims if they are “so related to claims in the action within such original jurisdiction that they form
part of the same case or controversy.” 28 U.S.C. § 1367 (a). “State and federal claims are part of
the same case or controversy if they derive from a common nucleus of operative facts.” Scholastic
Servs., Inc. v. First Midwest Bancorp, Inc., No. 2:15-CV-211, 2015 WL 5772526, at *3 (N.D. Ind.
Sept. 30, 2015). But federal courts can decline to exercise supplemental jurisdiction over the state
claims if (1) they raise “a novel or complex issue of state law,” (2) they “substantially
predominate” over the federal claims, (3) “the district court has dismissed all claims over which it
has original jurisdiction,” or (4) “there are other compelling reasons for declining jurisdiction.” 28
U.S.C. § 1367 (c). If a plaintiff believes removal was improper, they can move to remand the case
to state court. 28 U.S.C. § 1447 (c).
The Court agrees with Citibank that remand is not warranted here. The FDCPA is a federal
cause of action, meaning this Court has original jurisdiction over that claim. See 28 U.S.C. § 1331.
Groeneweg conceded in her Complaint that all her claims arise from Citibank’s attempt to collect
on Groeneweg’s debt. See generally ECF No. 4. The claims share this common nucleus of
operative fact and thus arise out of the same case or controversy. Thus, because the Court has
original jurisdiction over the FDCPA claim and the state law claims are part of the same case or
controversy, the Court can exercise supplemental jurisdiction over the state law claims unless
Groeneweg can show one of the exceptions applies.
Groeneweg’s only relevant2 argument opposing supplemental jurisdiction is that the state
claims—conversion, unjust enrichment, invasion of privacy, and intentional infliction of
emotional distress—substantially predominate over the FDCPA claim. She does not explain how
those claims substantially predominate, but the Court assumes that she believes the number of state
issues she brings outweighs the one federal issue. State issues only substantially predominate if
they require far more proof, involve issues of much greater scope, or seek a far more
comprehensive remedy, United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 726 (1966), none of
which exist here. Groeneweg has conceded that all her claims focus on the same conduct by
Citibank; thus, the same evidence would likely address nearly every issue on every claim. And
while she also seeks injunctive and declaratory relief for her claims, see ECF No. 4 at 21, those
remedies are within this Court’s capabilities. See Fed. R. Civ. P. 65; 28 U.S.C. §§ 2201–2202. Her
claim for intentional infliction of emotional distress would likely require evidence outside the
scope of her FDCPA claim, but that additional evidence is minimal compared to the vast majority
of evidence that would address all of her other claims, state and federal.
Finally, Groeneweg’s case presents no extraordinary circumstances that would justify
remand when this Court is otherwise the appropriate forum. Groeneweg argues that Citibank’s
parallel collection case against her in Allen Superior Court supports remand, as “[a]llowing
removal of only the plenary case, while Citibank’s collection action remains in state court, would
fracture a single controversy into two forums, create a substantial risk of inconsistent rulings on
ownership, standing, and the amount owed, and undermine judicial economy.”(ECF No. 5 at 4–
5). Generally, however, “the pendency of an action in the state court is no bar to proceedings
2 Groeneweg makes much to do about the low amount in controversy; however, because Citibank removed to this
Court based on federal question jurisdiction, the alleged amount in controversy is irrelevant, as federal question
jurisdiction includes no controversy requirement. See 28 U.S.C. § 1331.
concerning the same matter in the [f]ederal court having jurisdiction.” McClellan v. Carland, 217
U.S. 268, 282 (1910).
Here, although the two state actions were consolidated for the purposes of case
management and discovery, those cases retained separate cause numbers, dockets, and identities.
See Young Groeneweg v. Citibank NA, No. 02D03-2601-PL-000017, at 2/13/2026 “Order
Consolidating Cases”; see also Mich. City v. Hays-Republic Corp., 2020 WL 5757986, at *3 (N.D.
Ind. Sept. 28, 2020) (“The general rule under Indiana law is that consolidated cases retain their
separate identities.”). And while the cases might arise from a similar factual predicate—Citibank
attempting to collect Groeneweg’s credit card debt—and concern the same parties, there is nothing
to indicate that these cases are anything but separate, distinct actions.3 Ultimately, these two suits
are not, as Groeneweg asserts, “a single controversy,” and she has not demonstrated any valid
reason why her lawsuit cannot or should not continue in federal court.
For these reasons, Groeneweg’s Motion to Remand (ECF No. 5) is DENIED.
SO ORDERED this 7th day of April 2026.
s/Holly A. Brady
CHIEF JUDGE HOLLY A. BRADY
UNITED STATES DISTRICT COURT
3 Citibank’s debt collection action will require them to establish they have ownership of a debt and that debt has not
been paid; Groeneweg’s FDCPA claim will require establishing that the way Citibank went about collecting that
debt was unlawful—whether or not the collection action was meritorious in the first place.
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