Courtney Yackel et al. v. Rocket Mortgage, LLC

Summary

The United States District Court for the Eastern District of Texas reviews objections to a magistrate judge’s report recommending dismissal of claims against Rocket Mortgage, LLC. The court holds that documents attached to the complaint established a permissible purpose for obtaining Joel Yackel’s credit report under the Fair Credit Reporting Act and that amendment would be futile. Courtney Yackel’s FCRA claims are dismissed without prejudice for lack of standing, Joel Yackel’s FCRA claims are dismissed with prejudice for failure to state a claim, and the state-law claims are dismissed without prejudice for lack of pendent jurisdiction.

Holdings

1. At the motion-to-dismiss stage, the court may consider documents attached to the complaint that are central to the claim and referenced by the complaint, and may disregard allegations contradicted by facts established by those documents.
2. On the facts alleged and shown by the complaint's attachments, Rocket Mortgage had a permissible purpose to obtain Joel Yackel's credit report because he authorized the credit pull in connection with a loan application that remained under consideration.
3. Leave to amend was properly denied as futile where the documents already submitted by plaintiffs contradicted the allegations and established that the FCRA claim would remain subject to dismissal.
4. When all federal claims are dismissed before trial, pendent state-law claims generally should be dismissed without prejudice.

Questions Presented

1. Whether the magistrate judge improperly resolved factual disputes at the motion-to-dismiss stage by relying on documents attached to the complaint.
2. Whether authorization to obtain a credit report established a permissible purpose under the FCRA on the facts alleged and shown by the complaint's attachments.
3. Whether the district court should consider plaintiffs' objections based on arguments allegedly raised for the first time in the defendant's reply.
4. Whether plaintiffs should be granted leave to amend their claims.
5. Whether the state-law claims should be dismissed without prejudice for lack of pendent jurisdiction after dismissal of the federal claims.

Disposition

dismissed