HUNT v. EXPERIAN INFORMATION SOLUTIONS INC

CourtDistrict Court, M.D. Georgia
DecidedJanuary 15, 2025
Docket5:24-cv-00348
StatusUnknown

This text of HUNT v. EXPERIAN INFORMATION SOLUTIONS INC (HUNT v. EXPERIAN INFORMATION SOLUTIONS INC) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HUNT v. EXPERIAN INFORMATION SOLUTIONS INC, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION CRYSTAL HUNT, Plaintiff, v. CIVIL ACTION NO. 5:24-cv-00348-TES EXPERIAN INFORMATION SOLUTIONS INC., Defendant.

ORDER GRANTING MOTION TO COMPEL ARBITRATION

Plaintiff Crystal Hunt filed this action on October 7, 2024, alleging violations of the Fair Credit Reporting Act, 15 U.S.C. § 1681, (“FCRA”). See generally [Doc. 1]. In response, Defendant Experian Information Solutions, Inc. (“Experian”) filed a Motion to Compel Arbitration [Doc. 13]. BACKGROUND On June 8, 2021, Plaintiff signed up for free credit monitoring through Experian. [Doc. 13-1, ¶ 3]. To do so, Plaintiff created an account with CreditWorks and agreed to CreditWorks’ Terms of Use (the “Terms”). [Id. at ¶ 3]. The Terms included an arbitration clause requiring Plaintiff to litigate all claims against Experian1 in

1 The Terms explicitly reference “ECS,” which includes Experian “because it is an affiliate of ECS.” Pipoly v. Experian Info. Sols., Inc., No. 1:23-CV-925-MHC-CMS, 2023 WL 5184188, at *3 (N.D. Ga. Aug. 2, 2023). arbitration. [Id. at ¶ 6]. Now, skip forward a few months. On November 21, 2021, Plaintiff applied for a Sam’s Club credit card—through Synchrony Bank. [Doc. 1, ¶ 72].

After submitting her application, Plaintiff received notice that Experian reported her as deceased on her credit report, and consequently, Experian did not report a credit score in its file. [Id. at ¶ 73]. Following that report, Sam’s Club denied Plaintiff’s credit-card

application. [Id.]. Plaintiff contends that she chalked the report up as a simple mistake and moved on. [Id. at ¶ 75]. After receiving several pre-approval notices, Plaintiff then applied for a Capitol

One card. [Id. at ¶ 76]. Like Sam’s Club, Capitol One also denied Plaintiff’s application due to the lack of a credit score. [Id. at ¶ 78]. Again, “Plaintiff thought this was a simple mistake,” but became increasingly frustrated. [Id. at ¶ 80]. Next, Plaintiff attempted to use a new payment platform to pay her rent. [Id. at ¶

81]. On that platform, Plaintiff discovered she could use a service—Flexible Rent by Best Egg—to “pay rent on flexible terms.” [Id. at ¶ 82]. Plaintiff then applied for the Flexible Rent program. [Id. at ¶ 84]. Once more, Best Egg denied Plaintiff’s application because

Experian did not report a credit score. [Id. at ¶ 85]. Following the denial of her Flexible Rent application, Plaintiff’s property management company required her to prove she was not using a deceased person’s identity. Plaintiff contends that these accusations and misrepresentations on her credit report caused her to be “shocked and worried about

the possibility of becoming homeless due to being inaccurately reported as deceased.” [Id. at ¶ 91]. Ultimately, Plaintiff obtained a letter from the Social Security Administration proving that she was not deceased. [Id. at ¶ 93].

On September 8, 2024, Plaintiff obtained a copy of her Experian credit report, which showed an account held by Phillips Property, which reported Plaintiff to be deceased. [Id. at ¶ 97]. Plaintiff now brings a claim under FCRA alleging that Experian

“failed to follow reasonable procedures to assure maximum possible accuracy.” [Id. at p. 23 (capitalization altered)]. In response, Experian asks the Court to compel arbitration, citing the Terms

Plaintiff acknowledged when she signed up for CreditWorks. [Doc. 13, p. 14]. Hoping to avoid the outcome of many of her plaintiff-counterparts across the country, Plaintiff argues that “Experian cannot bear its burden of proving the formation and existence of a binding arbitration agreement.” [Doc. 14, p. 6].

In the Court’s view, tucking an arbitration clause behind a hyperlink and then burying it in dense mice-type brimming with mind-numbing legal jargon is a quintessential example of “[w]hat may be legal is not always right.” In re Graves Farms,

No. 18-10893, 2019 WL 3407134, at *8 (Bankr. D. Kan. July 26, 2019). But, the Court’s job is simply to apply the law and that it does in this case. LEGAL STANDARD2 Congress enacted the Federal Arbitration Act (“FAA”) “[t]o overcome judicial

resistance to arbitration.” Buckeye Check Cashing, Inc. v. Cardegna, 546 U.S. 440, 443 (2006). The FAA declares a “liberal federal policy favoring arbitration agreements.” Caley v. Gulfstream Aerospace Corp., 428 F.3d 1359, 1367 (11th Cir. 2005). Section 2 of the

FAA provides: A written provision in . . . a contract evidencing a transaction involving commerce to settle by arbitration a controversy thereafter arising out of such contract or transaction, or the refusal to perform the whole or any part thereof, or an agreement in writing to submit to arbitration an existing controversy arising out of such a contract, transaction, or refusal, shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.

9 U.S.C. § 2. Section 3 directs courts to stay proceedings in any case raising a dispute referrable to arbitration. 9 U.S.C. § 3. And Section 4 allows a court to issue an order compelling arbitration when parties do not comply with their arbitration agreement. 9 U.S.C. § 4. “Arbitration is a matter of contract and consent.” JPay, Inc. v. Kobel, 904 F.3d 923, 928 (11th Cir. 2018). “Arbitrators derive their authority to resolve disputes only because the parties have agreed in advance to submit such grievances to arbitration.” Id.

2 The standard for motions to compel is akin to the summary-judgment standard. Therefore, “a district court may conclude as a matter of law that parties did or did not enter into an arbitration agreement only if there is no genuine dispute as to any material fact concerning the formation of such an agreement.” Bazemore v. Jefferson Cap. Sys., LLC, 827 F.3d 1325, 1333 (11th Cir. 2016). (quoting AT&T Techs., Inc. v. Commc’ns Workers of Am., 475 U.S. 643, 648-49 (1986)). “Because of the FAA, federal courts are required to place arbitration clauses on equal

footing with other contracts.” Solymar Inv. v. Banco Santander S.A., 672 F.3d 981, 988 (11th Cir. 2012). Even so, federal courts must interpret arbitration clauses broadly where possible. Id. (citing AT&T Techs., 475 U.S. at 649-50).

To determine whether an enforceable arbitration agreement exists, the Court looks to Georgia law. See Caley v. Gulfstream Aerospace Corp., 428 F.3d 1359, 1368 (11th Cir. 2005) (“[S]tate law generally governs whether an enforceable contract or agreement

to arbitrate exists.”). Under Georgia law, a valid contract requires “parties able to contract, a consideration moving to the contract, the assent of the parties to the terms of the contract, and a subject matter upon which the contract can operate.” O.C.G.A.

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