Hebrank v. Early Warning Services LLC

CourtDistrict Court, D. Arizona
DecidedApril 18, 2025
Docket2:24-cv-03711
StatusUnknown

This text of Hebrank v. Early Warning Services LLC (Hebrank v. Early Warning Services LLC) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hebrank v. Early Warning Services LLC, (D. Ariz. 2025).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 Miah Ashton Hebrank, No. CV-24-03711-PHX-MTL 10 Plaintiff, ORDER 11 v. 12 Early Warning Services LLC, et al., 13 Defendants. 14 15 Before the Court is Defendant Early Warning Services, LLC’s (“EWS”) Motion to 16 Dismiss (Doc. 15) Plaintiff Hebrank’s Complaint. Having reviewed the Motion, and all 17 papers filed in connection, the Court finds that the Motion is suitable for disposition 18 without oral argument. See Partridge v. Reich, 141 F.3d 920, 926 (9th Cir. 1998); see also 19 Fed. R. Civ. P. 78(b); LRCiv 7.2(f). 20 I. BACKGROUND 21 The following factual summary is taken from the allegations in the Complaint, 22 which are presumed to be true for the purposes of assessing the pending motion. See 23 Manzarek v. St. Paul Fire & Marine Ins. Co., 519 F.3d 1025, 1031 (9th Cir. 2008). 24 EWS is a company which disseminates information regarding customer credit 25 history and other personal information, commonly known as a credit reporting agency 26 (“CRA”). (Doc. 1 at 2.) In May 2023, Wells Fargo denied Hebrank’s application to open a 27 deposit account. (Id. at 10-11.) On February 20, 2024, PNC Bank closed Hebrank’s PNC 28 account. (Id. at 12.) Because of this, Hebrank obtained her EWS customer report on March 1 4, 2024. (Id.) Upon reviewing this report, Hebrank noticed a Regions Bank account with 2 an outstanding amount and a notation of “checking account fraud” and “account abuse.” 3 (Id.) 4 Hebrank sent a written dispute to EWS regarding this report information on June 5 26, 2024. (Id. at 13.) EWS sent a letter to Hebrank on July 3, 2024, which describes the 6 procedures EWS uses to determine the accuracy of the information in a consumer report. 7 (Id. at 14-15.) Hebrank understood this letter as confirming that the information in EWS’s 8 report was accurate. (Doc. 20 at 3.) Hebrank alleges that as of July 12 and 17, 2024, EWS 9 was still reporting the inaccurate information on the report. (Doc. 1 at 15, 18.) On July 17, 10 2024, Hebrank sent a second dispute letter to EWS. (Id. at 18.) Hebrank alleges that, “[a]s 11 of October 4, 2024, Defendant EWS removed the inaccurate notations.” (Id. at 20.) On 12 December 27, 2024, Hebrank filed the Complaint, alleging violations under the Fair Credit 13 Reporting Act (“FCRA”), 15 U.S.C. § 1681 et seq. (Doc. 1.) 14 EWS filed the present Motion to Dismiss for failure to state a claim upon which 15 relief can be granted under Federal Rule of Civil Procedure 12(b)(6). EWS argues that (1) 16 Hebrank cannot state a § 1681i claim; (2) Hebrank cannot state a § 1681e claim; and (3) 17 Hebrank does not have an action generally because the information is not objectively and 18 readily verifiable. 19 II. LEGAL STANDARD 20 A motion to dismiss under Federal Rule of Civil Procedure 12(b)(6) for failure to 21 state a claim upon which relief can be granted “tests the legal sufficiency of a claim.” 22 Navarro v. Block, 250 F.3d 729, 732 (9th Cir. 2001). A court may dismiss a complaint “if 23 there is a lack of a cognizable legal theory or the absence of sufficient facts alleged under 24 a cognizable legal theory.” Conservation Force v. Salazar, 646 F.3d 1240, 1242 (9th Cir. 25 2011) (internal quotations and citation omitted). 26 A complaint must assert sufficient factual allegations that, when taken as true, “state 27 a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) 28 (internal quotations and citation omitted). Plausibility is more than mere possibility; a 1 plaintiff is required to provide “more than labels and conclusions, and a formulaic 2 recitation of the elements of a cause of action will not do.” Bell Atl. Corp. v. Twombly, 550 3 U.S. 544, 555 (2007). When analyzing the sufficiency of a complaint, the well-pled factual 4 allegations “are taken as true and construed in the light most favorable to the [plaintiff].” 5 Cousins v. Lockyer, 568 F.3d 1063, 1067 (9th Cir. 2009) (internal quotations and citation 6 omitted). 7 III. DISCUSSION 8 EWS moves to dismiss the two claims Hebrank brings under the FCRA. The first 9 claim pertains to EWS’s “reinvestigation” of the disputed accuracy, pursuant to § 1681i. 10 (Doc. 1 at 24-25.) The second claim pertains to EWS’s compliance procedures in 11 maintaining the accuracy of the initial report, pursuant to § 1681e. (Doc. 1 at 23-24.) EWS 12 also argues that Hebrank does not have actionable FCRA claims generally because the 13 report information is not objectively and readily verifiable. (Doc. 15 at 9-12.) 14 A. 15 U.S.C. § 1681i 15 Section §1681i states, in pertinent part: 16 [I]f the completeness or accuracy of any item of information contained in a consumer’s file at a consumer reporting agency 17 is disputed by the consumer and the consumer notifies the agency directly, or indirectly through a reseller, of such 18 dispute, the agency shall, free of charge, conduct a reasonable reinvestigation to determine whether the disputed information 19 is inaccurate and record the current status of the disputed information, or delete the item from the file in accordance with 20 paragraph (5), before the end of the 30-day period beginning on the date on which the agency receives the notice of the 21 dispute from the consumer or reseller. 22 15 U.S.C. § 1681i(a)(1)(A). To state a claim under § 1681i, Hebrank must sufficiently 23 allege the following: (1) she notified EWS of a disputed item of information; (2) EWS 24 failed to reinvestigate and either record the current status of the disputed information or 25 delete the disputed item from its files; (3) EWS’s failure to reinvestigate was negligent or 26 willful; and (4) EWS’s failure to reinvestigate caused Hebrank’s injuries. Acton v. Bank 27 One Corp., 293 F. Supp. 2d 1092, 1098-99 (D. Ariz. 2003). 28 EWS argues that the Court should dismiss Hebrank’s claim under § 1681i because 1 Hebrank cannot show that EWS failed to conduct a reinvestigation and resolve the dispute 2 within 30 days. (Doc. 15 at 6-7.) EWS attaches two exhibits to its Motion: the July 12, 3 2024 disclosure (Doc. 23 at 17-41, Exh. 4) and the July 15, 2024 disclosure (Doc. 23 at 43- 4 65), Exh. 5). According to EWS, the July 15 disclosure demonstrates that EWS conducted 5 a reasonable reinvestigation, and the disputed information was no longer found on 6 Hebrank’s account by July 15. (Doc. 15 at 7.) Hebrank argues that the Court cannot 7 consider these disclosures because they cannot be incorporated by reference into Hebrank’s 8 allegations. (Doc. 20 at 7.) EWS maintains that these disclosures should be incorporated 9 because they are documents Hebrank must “reference” and “directly discuss” in her 10 allegations. (Doc.

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Ashcroft v. Iqbal
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519 F.3d 1025 (Ninth Circuit, 2008)
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568 F.3d 1063 (Ninth Circuit, 2009)
Acton v. Bank One Corp.
293 F. Supp. 2d 1092 (D. Arizona, 2003)
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Henderson v. Henderson
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Bluebook (online)
Hebrank v. Early Warning Services LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hebrank-v-early-warning-services-llc-azd-2025.