Jefferson-James v. Portfolio Recovery Associates

CourtDistrict Court, W.D. Louisiana
DecidedOctober 4, 2024
Docket6:24-cv-00069
StatusUnknown

This text of Jefferson-James v. Portfolio Recovery Associates (Jefferson-James v. Portfolio Recovery Associates) is published on Counsel Stack Legal Research, covering District Court, W.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jefferson-James v. Portfolio Recovery Associates, (W.D. La. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

SHAYLA JEFFERSON-JAMES CASE NO. 6:24-CV-00069

VERSUS JUDGE TERRY A. DOUGHTY

PORTFOLIO RECOVERY ASSOCIATES MAGISTRATE JUDGE DAVID J. AYO

REPORT AND RECOMMENDATION

Before this Court is DEFENDANT’S MOTION TO DISMISS COMPLAINT AS TIME BARRED BY THE FAIR CREDIT REPORT ACT’S TWO YEAR STATUTE OF LIMITATIONS (Rec. Doc. 5) filed by Defendant Portfolio Recovery Associates, LLC. The motion is unopposed. The undersigned issues the following report and recommendation pursuant to 28 U.S.C. § 636. For the reasons explained below, this Court recommends that Portfolio’s motion be GRANTED and that Plaintiff Shayla Jefferson-James’ claims against Portfolio be DISMISSED WITH PREJUDICE. Factual Background On January 17, 2024, Plaintiff, proceeding pro se, filed a complaint in this Court against Portfolio alleging a violation of the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. (FCRA) (Rec. Doc. 1). She alleges that, on or about May 1, 2020, her credit report was generated (Id. at ¶ 5) which indicated that Portfolio had accessed her report on March 13, 2020 and March 15, 2020 (Id.).1 Portfolio allegedly did not have a “permissible purpose” as required by 15 U.S.C. § 1681b(f) to access her report. (Id. at ¶ 10). Plaintiff further alleges that Portfolio had not been retained by a creditor with whom she had initiated a transaction (Id. at ¶ 11), Portfolio did not take any follow-up actions after accessing the

1 The document attached to the complaint purporting to be a portion of Plaintiff’s credit report lists an additional access date of August 5, 2018. (Rec. Doc. 1-2). report (Id. at ¶ 12), and Plaintiff had not given consent to Portfolio to access her report (Id. at ¶ 13). Portfolio’s lack of a permissible purpose is alleged to constitute a violation of the FCRA for which she seeks actual and punitive damages. (Id. at Prayer). Portfolio responded with the instant motion contending that Plaintiff’s suit is untimely under the FCRA’s two-year statute of limitations. (Rec. Doc. 5) (citing 15 U.S.C. § 1681p). In support, Portfolio submitted the affidavit of Meryl Dreano, Portfolio’s custodian of records, who attested to the presence in Portfolio’s files of a June 26, 2020 letter from

Plaintiff addressed to Portfolio stating as follows: “I’m writing to ask what was your permissible purpose for pulling my Transunion credit report on 03/15/2020, 03/13/2020, and 08/05/2018? To my knowledge, we have not done any type of business.” (Affidavit, Rec. Doc. 5-2, Letter, Rec. Doc. 5-3). Plaintiff did not respond to the motion. Applicable Standards When considering a motion to dismiss for failure to state a claim under Fed. R. Civ. P. Rule 12(b)(6), a district court must limit itself to the contents of the pleadings, including any attachments thereto. Collins v. Morgan Stanley Dean Witter, 224 F.3d 496, 498 (5th Cir. 2000). The court must accept all well-pleaded facts as true and view them in the light most favorable to the plaintiff. In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007) (internal quotations omitted) (quoting Martin K. Eby Constr. Co. v. Dallas Area Rapid Transit, 369 F.3d 464, 467 (5th Cir. 2004)); Baker v. Putnal, 75 F.3d 190, 196 (5th Cir. 1996). However, conclusory allegations and unwarranted deductions of fact are not accepted as true, Kaiser Aluminum & Chem. Sales v. Avondale Shipyards, 677 F.2d 1045, 1050 (5th Cir. 1982) (citing Associated Builders, Inc. v. Alabama Power Co., 505 F.2d 97, 100 (5th Cir. 1974)); Collins v. Morgan Stanley, 224 F.3d at 498. Courts “are not bound to accept as true a legal conclusion couched as a factual allegation.” Bell Atl. Corp. v. Twombly, 550 U.S. at 555 (quoting Papasan v. Allain, 478 U.S. 265, 286 (1986)). To survive a Rule 12(b)(6) motion, the plaintiff must plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atl., 127 U.S. at 570. The allegations must be sufficient “to raise a right to relief above the speculative level,” and “the pleading must contain something more . . . than . . . a statement of facts that merely creates a suspicion [of] a legally cognizable right of action.” Id. at 555 (quoting 5 C. Wright & A. Miller, Federal

Practice and Procedure § 1216, pp. 235-36 (3d ed. 2004)). “While a complaint . . . does not need detailed factual allegations, a plaintiff’s obligation to provide the grounds of his entitlement to relief requires more than labels and conclusions, and a formulaic recitation of the elements of a cause of action will not do.” Id. (citations, quotation marks, and brackets omitted; emphasis added). See also Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). If the plaintiff fails to allege facts sufficient to “nudge[ ][his] claims across the line from conceivable to plausible, [his] complaint must be dismissed.” Bell Atl., 127 U.S. at 570. A claim meets the test for facial plausibility “when the plaintiff pleads the factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. at 678. “[D]etermining whether a complaint states a plausible claim for relief . . . [is] a context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. at 679. Therefore, “[t]he complaint (1) on its face (2) must contain enough factual matter (taken as true) (3) to raise a reasonable hope or expectation (4) that discovery will reveal relevant evidence of each element of a claim.” Lormand v. US Unwired, Inc., 565 F.3d 228, 257 (5th Cir. 2009) (quoting Bell Atl., 127 U.S. at 556). See also In Re Southern Scrap, 541 F.3d 584, 587 (5th Cir. 2008). Ordinarily, in ruling on a Rule 12(b)(6) motion, the Court is limited to the allegations of the complaint and any exhibits attached thereto; however, the court may also consider documents attached to the defendant’s motion if they are referenced in the complaint and central to the plaintiff’s claims. In re Katrina Canal Breaches Litig., 495 F.3d 191, 205 (5th Cir. 2007). The Court is also permitted to take judicial notice of public records as well as facts which are not subject to reasonable dispute in that they are either (1) generally known within the territorial jurisdiction of the trial court or (2) capable of

accurate and ready determination by resort to sources whose accuracy cannot reasonably be questioned. Funk v.

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Related

Baker v. Putnal
75 F.3d 190 (Fifth Circuit, 1996)
Collins v. Morgan Stanley Dean Witter
224 F.3d 496 (Fifth Circuit, 2000)
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Lormand v. US Unwired, Inc.
565 F.3d 228 (Fifth Circuit, 2009)
Papasan v. Allain
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Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ronald Funk v. Stryker Corporation
631 F.3d 777 (Fifth Circuit, 2011)
Stanley J. Stewart v. Parish of Jefferson
951 F.2d 681 (Fifth Circuit, 1992)
Heriberto Huerta v. Marcia Shein
498 F. App'x 422 (Fifth Circuit, 2012)
In Re Katrina Canal Breaches Litigation
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Jefferson-James v. Portfolio Recovery Associates, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jefferson-james-v-portfolio-recovery-associates-lawd-2024.