Potapova v. Toyota Motor Credit Corporation

Background

Iuliia Potapova sued Toyota Motor Credit Corporation (TMCC) under the Fair Credit Reporting Act, a federal law governing the accuracy of consumer-credit information and investigations of disputes. Trial was scheduled to begin on May 6, 2025. Before trial, both sides filed motions in limine, which are requests to decide in advance whether certain evidence or arguments may be presented to the jury.

The court noted that it had previously denied TMCC’s motion for summary judgment. That earlier ruling did not grant summary judgment to Potapova and did not prevent TMCC from presenting evidence at trial to fill an evidentiary gap.

Plaintiff’s Motions

1. Investigation by Christopher Blunt or TMCC’s Fraud Department — denied. The court held that evidence showing TMCC considered the Blunt investigation when investigating an Automated Credit Dispute Verification report could be relevant to whether TMCC’s investigation was reasonable. Its value was not substantially outweighed by the risk of unfair prejudice or other concerns under Evidence Rule 403.

2. Blunt’s notes about police or dealership statements — denied. The notes could be admitted as evidence of TMCC’s investigation or to show the effect of the statements on the person hearing them, rather than to prove that the statements were true. The court said it would instruct the jury accordingly.

3. Whether Potapova had to prove identity theft — denied. The court held that Potapova must prove she was the victim of identity theft to prevail on her Fair Credit Reporting Act claim because her claim is based on the assertion that the reported credit information was inaccurate for that reason.

4. TMCC’s interpretation of the Fair Credit Reporting Act — denied. The court denied the motion for the reasons substantially stated in TMCC’s opposition.

5. Settlement with another entity — denied as unripe and premature. Potapova represented that she currently had no settlements with other entities. If she reached a settlement before trial and TMCC sought to introduce evidence of it, TMCC would have to give advance notice to Potapova and the court.

6. Other litigation involving Potapova — granted. The court barred reference to her other litigation because its limited relevance was substantially outweighed by the risks of unfair prejudice, confusing the issues, delaying the trial, and wasting time.

7. Number or nature of cases handled by Potapova’s lawyers or their firms — granted. The court held that counsel’s experience in other matters was not relevant to the issues in dispute. Any limited relevance was substantially outweighed by the risks identified under Evidence Rules 401 through 403.

Defendant’s Motions

1. Actual and economic damages — denied. The court rejected TMCC’s request to bar evidence or argument supporting Potapova’s damages claim, describing it as a belated attempt to revisit an issue addressed when the court denied TMCC’s summary-judgment motion.

2. What TMCC knew or should have known when the lease was made — denied. The court said the trial should focus on whether TMCC reasonably investigated the Automated Credit Dispute Verification reports, not on whether TMCC acted reasonably when it first accepted the lease. However, limited evidence about what TMCC did or did not have in its files could be relevant to the reasonableness of its later investigations. The court said limiting instructions could address the evidentiary concerns.

3. Vehicle status, repossession, sale, or remaining balance — granted. The court barred this evidence or argument because what happened to the vehicle after TMCC’s investigations had little or no relevance to the disputed issues, and any probative value was substantially outweighed by the risks of unfair prejudice, confusion, and wasted time.

4. Reports concerning Buyer Sanat Yarmukhamedov and his financial difficulties — judgment reserved. The court deferred ruling until discussion with the parties at the final pretrial conference scheduled for May 1, 2025.

5. Contract elements — denied as moot. Potapova represented that she would not argue that TMCC had to prove the elements of a contract as part of its defense. The court therefore denied the motion as moot. The ruling did not prevent Potapova from presenting evidence that she never signed or agreed to the lease, which the court said was central to her identity-theft and inaccurate-credit-information claims.

Disposition

The court granted Plaintiff’s Motions in Limine Nos. 6 and 7; denied Plaintiff’s Motions in Limine Nos. 1 through 5, with Motion No. 5 denied as unripe and premature; denied Defendant’s Motions in Limine Nos. 1 and 2; granted Defendant’s Motion in Limine No. 3; reserved judgment on Defendant’s Motion in Limine No. 4; and denied Defendant’s Motion in Limine No. 5 as moot. The Clerk of Court was directed to terminate the two motion filings. This order addressed trial evidence and did not determine the ultimate outcome of the underlying claims.