Ball v. Barclays Bank Delaware

CourtDistrict Court, D. Nevada
DecidedJanuary 2, 2025
Docket2:24-cv-01452
StatusUnknown

This text of Ball v. Barclays Bank Delaware (Ball v. Barclays Bank Delaware) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ball v. Barclays Bank Delaware, (D. Nev. 2025).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 WILLIAM H. BALL, Case No. 2:24-cv-1452-CDS-EJY 4 Plaintiff, ORDER 5 v. AND 6 BARCLAYS BANK DELEWARE, a REPORT AND RECOMMENDATION 7 Delaware corporation. Re: ECF Nos. 1, 1-1 8 Defendant.

9 10 Pending before the Court is Plaintiff’s application to Proceed in formal pauperis (“IFP”) and 11 Complaint. ECF Nos. 1, 1-1. Plaintiff’s IFP application is complete and granted below. Plaintiff’s 12 Complaint is dismissed in part without prejudice and with leave to amend. Plaintiff’s state law 13 claims are preempted and, therefore, the Court recommends these claims be dismissed with 14 prejudice. 15 I. Screening Standard 16 When screening a complaint, the Court must identify cognizable claims and dismiss claims 17 that are frivolous, malicious, fail to state a claim upon which relief may be granted or seek monetary 18 relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2). Dismissal for 19 failure to state a claim under § 1915(e)(2) incorporates the standard for failure to state a claim under 20 Federal Rule of Civil Procedure 12(b)(6). Watison v. Carter, 668 F.3d 1108, 1112 (9th Cir. 2012). 21 To survive § 1915 review, a complaint must “contain sufficient factual matter, accepted as true, to 22 state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). The 23 court liberally construes pro se complaints and may only dismiss them “if it appears beyond doubt 24 that the plaintiff can prove no set of facts in support of his claim which would entitle him to relief.” 25 Nordstrom v. Ryan, 762 F.3d 903, 908 (9th Cir. 2014) (quoting Iqbal, 556 U.S. at 678). 26 In considering whether the complaint is sufficient to state a claim, all allegations of material 27 fact are taken as true and construed in the light most favorable to the plaintiff. Wyler Summit P’ship 1 v. Turner Broad. Sys. Inc., 135 F.3d 658, 661 (9th Cir. 1998) (citation omitted). Although the 2 standard under Rule 12(b)(6) does not require detailed factual allegations, a plaintiff must provide 3 more than mere labels and conclusions. Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555 (2007). 4 A formulaic recitation of the elements of a cause of action is insufficient. Id. Unless it is clear the 5 complaint’s deficiencies cannot be cured through amendment, a pro se plaintiff should be given 6 leave to amend the complaint with notice regarding the complaint’s deficiencies. Cato v. United 7 States, 70 F.3d 1103, 1106 (9th Cir. 1995). 8 II. Review of Plaintiff’s Complaint 9 Plaintiff’s Complaint includes three causes of action arising from what appears to be 10 Defendant Barclays Bank (“Barclays”) alleged violation of the Fair Credit Reporting Act (the 11 “FCRA”). That is, Plaintiff says Barclays allegedly and wrongfully reported responsibility for a 12 debt Plaintiff says he does not owe. 13 Despite Plaintiff’s failure to identify under what section of the FCRA he is proceeding, 15 14 U.S.C. § 1681s-2(b) provides furnishers1 of credit reports have a duty to “conduct an investigation” 15 after receiving “notice ... of a dispute with regard to the completeness or accuracy of any information 16 provided ... to a consumer reporting agency.” To this end, Plaintiff complains (1) Barclays furnished 17 credit reporting agencies erroneous credit information, (2) he wrote to Barclays about an account 18 listed on a credit report that erroneously identified him as an authorized user and owing a debt, (3) 19 Barclays knew Plaintiff was not responsible for the debt it reported he owed, and (4) the erroneous 20 report interfered with Plaintiff’s ability to get financing to purchase a home in Nevada.

21 A. Plaintiff’s FCRA Claim is Dismissed Without Prejudice and With Leave to Amend. 22 The Court liberally construes Plaintiff’s FCRA claim against Barclays as one alleging a 23 failure to conduct a reasonable investigation after receiving notice of his dispute with regard to the 24 accuracy of information provided by Barclays to consumer reporting agencies. A consumer—such 25 as Plaintiff—may sue a furnisher of information—such as Barclays—and recover damages if the 26 1 15 U.S.C. § 1681s-2(a) of the FCRA defines “furnisher” by stating: “A person shall not furnish any 27 information relating to a consumer to any consumer reporting agency if the person knows or has reasonable cause to believe that the information is inaccurate.” 1 furnisher willfully or negligently violated the FCRA. 15 U.S.C. §§ 1681n, 1681o; Syed v. M-I, LLC, 2 853 F.3d 492, 503 (9th Cir. 2017). In such lawsuits, before a court will consider the reasonableness 3 of investigatory procedures, the plaintiff must make a “prima facie showing” of inaccuracy in the 4 information reported. Gross v. CitiMortgage, Inc., 33 F.4th 1246, 1251 (9th Cir. 2022) citing Shaw 5 v. Experian Info. Sols., Inc., 891 F.3d 749, 756 (9th Cir. 2018) (quoting Carvalho v. Equifax Info. 6 Servs., LLC, 629 F.3d 876, 890 (9th Cir. 2010)). If the consumer (plaintiff) establishes a prima facie 7 showing of inaccuracy, the plaintiff must establish the investigation conducted by the furnisher was 8 unreasonable. Id. 9 Here, Plaintiff does not establish a prima facie case of inaccuracy. Stated simply, Plaintiff’s 10 allegations are conclusory. That is, Plaintiff states, more than once, that he was not an authorized 11 user and is not responsible for the debt reported by Barclays. Plaintiff’s personal opinion is 12 “insufficient to support a claim of inaccuracy under the FCRA.” Gomez v. EOS CCA, Case No. CV- 13 18-02740-PHX-JAT (DMF), 2020 WL 3271749, at *3 (D. Ariz. June 17, 2020) (collecting cases). 14 Some of the authorities on which the court in Gomez relied stated this standard “in the context of a 15 motion to dismiss.” Id. The court explained “a consumer’s failure to explain or cite evidence 16 showing an inaccuracy is fatal to an FCRA claim” at the motion to dismiss stage (as well as “‘a 17 fortiori’ at the summary judgment stage”). Id. 18 Plaintiff provides no substantive facts, documents or evidence in support of the alleged 19 inaccuracy of the credit report at issue. ECF No. 1-1. Plaintiff’s conclusions fail to state a claim 20 against Barclays under the FCRA. However, this claim is capable of cure through amendment. 21 Thus, the Court dismisses Plaintiff’s FCRA claim against Barclays without prejudice and with leave 22 to amend. 23 B. Plaintiff’s Defamation and Fraud Claims are Preempted by the FCRA. 24 “[T]he FCRA contains two preemption sections restricting state law claims that apply to 25 persons who furnish information under the FCRA.” Woods v. Prot.

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Ball v. Barclays Bank Delaware, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ball-v-barclays-bank-delaware-nvd-2025.