Carroll v. EQUIFAX INFORMATION SERVICES LLC

Background

Estelle Kevett Carroll, representing herself and proceeding without paying the filing fee, sued Equifax Information Services LLC under the Fair Credit Reporting Act (FCRA). Carroll alleged that a credit report she requested on February 16, 2025, contained inaccurate and incomplete information about her name, date of birth, addresses, and at least eight financial accounts. She also alleged that she reported the inaccuracies to Equifax and asked the company to investigate and correct them.

Carroll claimed that Equifax failed to conduct reasonable investigations, failed to maintain reasonable procedures for accurate reporting, and willfully or negligently reported inaccurate credit information. She alleged that the inaccuracies affected her reported credit score and sought money damages.

Court’s Analysis

The court explained that a plaintiff bringing an FCRA claim must have standing, meaning a concrete injury connected to the defendant’s conduct that a court can remedy. The court held that Carroll’s allegations did not show a concrete injury. Her complaint alleged inaccurate information and an effect on her credit score, but did not allege that Equifax disclosed inaccurate information to a third party, that she was denied credit, or that she received less favorable credit terms because of the information.

Because Carroll did not adequately allege a concrete injury, the court concluded that she lacked standing and that it lacked subject-matter jurisdiction over her FCRA claims. The court therefore did not reach whether Equifax violated the FCRA’s requirements concerning accuracy, investigations, or reporting procedures.

Disposition

Judge Gregory H. Woods dismissed the complaint without prejudice for lack of subject-matter jurisdiction and granted Carroll 30 days’ leave to replead. If she does not file an amended complaint within that period, the clerk will be directed to enter judgment. The court also certified that an appeal would not be taken in good faith and denied Carroll permission to proceed without paying fees for an appeal. The clerk was directed to keep the matter open until a civil judgment is entered.