On April 13, the U.S. District Court for the Eastern District of New York granted summary judgment in favor of the defendant and dismissed a plaintiff’s claims alleging negligent and willful violations of the FCRA’s § 1681s-2(b) duty to investigate disputed credit information. The plaintiff alleged that a retail installment contract for an auto loan was fraudulently opened in his name in December 2019 and that the defendant, a furnisher of credit information, failed to conduct a reasonable investigation after receiving an indirect dispute notice from a credit reporting agency in July 2025. The plaintiff’s 2025 dispute included an FTC identity theft report, identification documents, and a dispute letter — a more detailed submission than his prior disputes. The plaintiff had submitted multiple prior disputes between June 2020 and May 2023 claiming identity theft or fraud but never provided documentation substantiating those claims.

The court held that the defendant’s investigation was objectively reasonable as a matter of law. Upon receiving the July 2025 dispute, the defendant’s investigator verified that the plaintiff’s name, middle initial, Social Security number, and driver’s license number on the account origination documents matched the information provided in the dispute, compared signatures on the origination documents to the plaintiff’s identification and found them “very similar,” and noted that timely payments had been made on the account — which the court observed is generally inconsistent with fraud. The court emphasized that the investigation exceeded what was required, noting it “could have reasonably ended” at earlier stages but “went further” each time. The court also held that the plaintiff’s own affidavit denying he signed a contract, “without more,” does not demonstrate that the furnisher failed to conduct a reasonable investigation, warning that such a standard would allow consumers to erase legitimate debts by falsely asserting fraud.

The court further held that the defendant’s subsequent decision in August 2025 to delete the account did not render the earlier investigation unreasonable, noting that such a conclusion would disincentivize furnishers from taking proactive steps to resolve disputes with consumers. The court also rejected the plaintiff’s argument that the defendant violated § 1681s-2(b) by failing to mark the account as disputed, finding that this obligation falls under § 1681s-2(a), for which there is no private right of action.