On February 4, the U.S. District Court for the Middle District of Florida dismissed a pro se plaintiff’s complaint alleging violations of the FCRA against a consumer reporting agency. The plaintiff claimed the agency willfully violated 15 U.S.C. §§ 1681e(b), 1681i(a) and 1681g by reporting her Chapter 7 bankruptcy with the abbreviation “US BKPT CT FL TAMPA” and retaining an unspecified “[a]ddress ID metadata field.” The plaintiff alleged $10,000 in damages for emotional distress following her bankruptcy filing on July 23, 2020, and discharge on October 27, 2020. The court determined that she had Article III standing based on her claims of emotional distress and the time spent disputing the alleged inaccuracies but concluded that she failed to state a claim under any of the cited provisions.

The court found no factual inaccuracy in the agency’s report, noting that the plaintiff did not allege active debts, balances owed, or past-due amounts after discharge. It held that the use of abbreviations and internal metadata did not constitute inaccuracies under §§ 1681e(b) or 1681i. Further, the court dismissed her § 1681g claim because she never requested her consumer file through the statutory process; instead, she obtained internal data through unrelated litigation discovery. Without evidence of inaccurate reporting or statutory violations, the court granted the defendant’s motion to dismiss all counts.