Plaintiffs filed a class action lawsuit challenging "Citi ATM Community Network," which allows customers of participating minority-owned banks to withdraw cash without paying out-of-network ATM fees at Citibank ATMs.

Plaintiffs allege that Defendant's policy is race discrimination in violation of section 1981.

Defendant argues that the case should be dismissed because Plaintiffs lack standing to sue. Defendant argues that to bring a section 1981 claim, claimants must be "able and ready" to enter into a contract from which they claim they were excluded on account of race. However, according to Defendants, the ATM Community Network does not offer a fee waiver on a customer-by-customer basis, so Plaintiffs are not "able and ready" to join the Network on their own, nor could they allege that their banks are "able and ready" to join.

On March 28, 2025 the court granted Defendant’s motion to dismiss because Plaintiffs lacked standing due to the court not considering them harmed by the out-of-network ATM Fees. Since Plaintiffs are customers of Defendant’s competitors, they would pay the out-of-network fees even if the ATM Community Network Program didn’t exist. Secondly, the ATM Community Network Program fee waivers cannot be opted into by individuals. Instead, Plaintiffs' financial institutions must agree to the terms set by Defendant in order to participate. However, Plaintiffs were unable to show that their financial institutions were “able and ready” to apply to the program.