Bryson v. TransUnion LLC
- David Doty
- 0:25-cv-01717
- U.S. District Court · District of Minnesota
- 5
In Bryson v. Trans Union LLC, Judge Doty dismissed with prejudice pro se plaintiff Brandon Bryson's credit-reporting claims for failing to allege specific inaccuracies.
Consumers who file pro se lawsuits under the Fair Credit Reporting Act or Fair Debt Collection Practices Act and may need to understand what specific factual allegations — such as identifying which reported information was inaccurate and when — are required to survive a motion to dismiss.
What happened
In Bryson v. Trans Union LLC, No. 25-1717, pro se plaintiff Brandon Bryson sued Trans Union, LLC and Transworld Systems, Inc., claiming they violated two federal consumer-protection laws — the Fair Credit Reporting Act (FCRA) and the Fair Debt Collection Practices Act (FDCPA) — by reporting inaccurate, outdated, and misleading information on his credit report. Bryson alleged he suffered serious harm, including loan denials, a car repossession, and a threat of eviction, and he sought money damages and a court order stopping the defendants' conduct.
Both defendants moved to dismiss, arguing that Bryson's complaint was too vague to state a valid legal claim. The court found that Bryson never identified what specific information was inaccurate, when it was reported, or how the defendants failed to follow proper procedures — essentially all of the factual details needed to support his claims. The court also struck a second amended complaint that Bryson filed without the court's permission, as required by the rules.
Judge David S. Doty granted both motions to dismiss and dismissed the entire case with prejudice, meaning Bryson cannot refile these claims. The judge noted that Bryson had submitted three complaints and multiple briefs without ever coming close to properly stating a legal claim, and therefore saw no basis to allow further attempts to amend.
The detailed version
- Bryson v. TransUnion LLC · No. 0:25-cv-01717
- David Doty
- Sept. 30, 2025
Background
Pro se plaintiff Brandon Bryson filed an amended complaint on May 8, 2025, against defendants Trans Union, LLC and Transworld Systems, Inc. Bryson alleged violations of the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., which governs the accuracy of consumer credit reports, and the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. § 1682 et seq., which regulates debt-collection conduct.
Bryson claimed that Trans Union reported "inaccurate, re-aged, and previously disputed accounts" on his credit report, and that Transworld reported "false or misleading information regarding debt allegedly owed, including outdated balances, misdated activity, and failure to verify debts upon dispute." He named several accounts but did not describe what was inaccurate about them or when the allegedly defective information was reported. He alleged that defendants failed to correct the data despite his attempt to arbitrate the dispute. Bryson sought actual damages, statutory damages, punitive damages, and injunctive relief, citing psychological and emotional distress, denial of loans and credit, car repossession, and threat of eviction.
After Trans Union filed its motion to dismiss, Bryson filed a second amended complaint without seeking leave of court, in violation of Federal Rule of Civil Procedure 15(a)(2), which requires court permission after an initial amendment.
Legal Standard
The court applied the standard for dismissal under Federal Rule of Civil Procedure 12(b)(6) — failure to state a claim upon which relief can be granted. Under this standard, a complaint must contain sufficient factual matter, accepted as true, to state a claim that is plausible on its face. The court cited Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007). Labels, conclusions, and formulaic recitations of elements are not enough. Because Bryson was proceeding without a lawyer (pro se), the court applied a liberal construction standard, dismissing only if it appeared beyond doubt that Bryson could allege no set of facts supporting jurisdiction or relief.
Analysis
The court identified the elements Bryson needed to allege to state a claim under the FCRA (citing Paul v. Experian Info. Servs., Inc., 793 F. Supp. 2d 1098, 1101 (D. Minn. 2011)):
- Defendants failed to follow reasonable procedures intended to assure the accuracy of their reports;
- Defendants reported inaccurate credit information about Bryson;
- Bryson suffered harm; and
- Defendants' failure to follow reasonable procedures caused that harm.
The court found that Bryson alleged only harm (element 3) and failed to plead any of the remaining required elements. Because he did not identify specific inaccuracies, did not explain when the information was reported, and did not describe how defendants' procedures were deficient, there was nothing for the court to assess or construe in his favor.
The court also struck the second amended complaint (ECF No. 27) as improperly filed without leave of court. The court added that, even if considered, the second amended complaint would still fail to meet pleading standards.
Disposition
Judge Doty granted both motions to dismiss (ECF Nos. 21 and 31), struck the second amended complaint from the docket, and dismissed the case with prejudice. The court expressly noted that Bryson had submitted three complaints and multiple briefs without ever coming close to properly stating a legal claim, justifying dismissal with prejudice rather than allowing further amendment.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.