Keonna Campbell v. Trans Union, LLC

Summary

The United States District Court for the Middle District of Georgia granted Trans Union, LLC’s motion for judgment on the pleadings in an action alleging violations of the Fair Credit Reporting Act. The court held that the consumer report, viewed in its entirety, was not objectively inaccurate or misleading because it indicated that the account had been charged off but was paid in full and had a zero balance. Plaintiff’s claims under 15 U.S.C. §§ 1681e(b) and 1681i were dismissed without prejudice, and leave to amend was denied.

Holdings

1. The court may consider the August 2024 consumer report without converting the Rule 12(c) motion into a summary judgment motion because Campbell referred to the report, it was central to her claims, its contents were not disputed, and Trans Union attached it to the motion.
2. Campbell failed to plead facts showing that Trans Union reported inaccurate information, and therefore failed to state claims under 15 U.S.C. §§ 1681e(b) and 1681i.
3. Because Campbell failed to adequately plead a violation of §§ 1681e(b) or 1681i, she also failed to adequately plead willfulness supporting punitive damages under 15 U.S.C. § 1681n.
4. The court denied Campbell's request for leave to amend because she did not file a motion for leave, did not provide the substance of a proposed amendment, and gave no reason to believe additional facts could cure the deficiencies.

Questions Presented

1. Whether Campbell sufficiently pleaded an inaccuracy in Trans Union's consumer report to state claims under 15 U.S.C. §§ 1681e(b) and 1681i.
2. Whether the August 2024 consumer report could be considered on a Rule 12(c) motion without converting the motion to one for summary judgment.
3. Whether Campbell adequately pleaded willfulness supporting punitive damages under 15 U.S.C. § 1681n.
4. Whether Campbell should be granted leave to amend her complaint.

Disposition

dismissed