Background
Reginald Lamar Williams, acting pro se, filed a complaint in Montgomery County Common Pleas Court on January 2, 2026 against U.S. National Bank Association. The complaint was a fill-in-the-blank form containing only two sentences, which vaguely alleged that a court had previously awarded Williams $12 billion for a Consumer Sales Practices Act (CSPA) violation by a bank employee. Williams sought $21,818,181,818 in damages. The complaint contained no factual allegations describing what U.S. National had done to him or any basis for a legal claim.
U.S. National moved to dismiss under Ohio Civil Rule 12(B)(6) for failure to state a claim. Williams responded with a “Dismissal Request” that did not address the 12(B)(6) argument but instead focused on a subpoena he had issued for phone records. On January 27, 2026, the trial court granted the motion, finding the complaint failed to comply with Civil Rule 8(A)’s requirement of a short and plain statement showing entitlement to relief. Williams appealed, raising two assignments of error.
The Court’s Holding
The Second District affirmed the dismissal on both grounds raised by the trial court. First, the court conducted a de novo review and found that Williams’ two-sentence complaint contained no factual allegations sufficient to state any claim, including a CSPA violation. The court noted that additional facts Williams raised in his appellate brief — that he had sought financial assistance from U.S. National for a business venture and was denied — were never included in the complaint and therefore could not save it.
The court further held that even if the complaint had been liberally construed as alleging a CSPA claim, dismissal was still required as a matter of law. Under R.C. 1345.01(A), the CSPA applies only to “consumer transactions,” and that definition expressly excludes transactions between financial institutions — as defined under R.C. 5725.01, which includes national banks like U.S. National — and their customers. Because U.S. National is a national bank and therefore a financial institution, no transaction between it and Williams could qualify as a consumer transaction under the CSPA.
On Williams’ second assignment of error, the court rejected the argument that the trial court should have afforded him greater leniency as a pro se litigant. While acknowledging that courts may liberally construe pro se complaints when the language permits it, the court distinguished that practice from reading factual claims into a complaint that contains none at all. The court reaffirmed that pro se litigants are held to the same procedural standards as represented parties.
Key Takeaways
- A complaint that consists of only two vague sentences with no factual allegations fails Ohio’s notice-pleading standard under Civ.R. 8(A) and is properly dismissed under Civ.R. 12(B)(6).
- The Ohio CSPA does not cover transactions between financial institutions (including national banks under R.C. 5725.01) and their customers — claims arising from banking relationships cannot proceed under ORC Chapter 1345 absent an applicable statutory exception.
- Facts raised for the first time in an appellate brief cannot cure a deficient complaint; the sufficiency of the complaint is judged on its face.
- Pro se status does not relax pleading requirements in Ohio; courts may liberally read allegations that exist, but they are not required to invent allegations that do not.
Why It Matters
This decision is a straightforward but useful reminder of two distinct barriers that CSPA plaintiffs face when suing banks. Even a well-pleaded complaint alleging consumer-protection violations would fail against a national bank because such institutions are categorically excluded from the CSPA’s definition of “consumer transaction.” Attorneys advising clients who have grievances against banks should look to other statutory frameworks — such as federal banking regulations or the Ohio common law of contract and fraud — rather than the CSPA.
The case also reinforces Ohio’s consistent position that pro se litigants receive no special dispensation from pleading rules. Courts will not speculate or fill gaps in a factually empty complaint, regardless of whether the plaintiff is represented. For practitioners, the opinion illustrates the ceiling of liberal construction: it aids interpretation of existing allegations, but it is not a license to create a cause of action from a blank page.