Dreher v. Experian Information Solutions, No. 15-2119 (4th Cir. 2017)Annotate this Case
Where an individual fails to allege a concrete injury stemming from allegedly incomplete or incorrect information listed on a credit report, he or she cannot satisfy the threshold requirements of constitutional standing. At issue in this case was whether the decision of Experian to list a defunct credit card company, rather than the name of its servicer, as a source of information on an individual's credit report -- without more -- created sufficient injury in fact under the Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681g(a)(2), for purposes of Article III standing. The Fourth Circuit found no concrete injury on behalf of plaintiff because he was not adversely affected by the alleged error on his credit report. Therefore, the Fifth Circuit vacated the district court's denial of Experian's motion for summary judgment and remanded with instructions that the case be dismissed.