Taylor v. Tenant Tracker, Inc., No. 11-3466 (8th Cir. 2013)
Annotate this CasePlaintiff sued Tenant Tracker alleging that it failed to adopt reasonable procedures to ensure maximum possible accuracy of its credit reporting, in violation of the Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681 et seq. Plaintiff claimed that Tenant Tracker violated the FCRA by including entries in her credit report that did not accurately reflect her own background. The court held that plaintiff did not present competent evidence that she suffered actual damages under the FCRA where the only alleged harm she suffered was emotional injury. The corroboration of a brief episode of frustration and unhappiness did not constitute a genuine injury and actual damages. Accordingly, the court affirmed the district court's dismissal of her suit.
Court Description: Civil case - Fair Credit Reporting Act. Plaintiff failed to show she suffered "actual damages" from any violation of the FCRA, as a brief episode of frustration and unhappiness over an incorrect report did not establish the sort of concrete emotional distress that is required to constitute a genuine injury and actual damages.
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