Kodrick v. Ferguson

54 F. Supp. 2d 788, 1999 U.S. Dist. LEXIS 1806, 1999 WL 98020
CourtDistrict Court, N.D. Illinois
DecidedFebruary 16, 1999
Docket98 C 576
StatusPublished
Cited by11 cases

This text of 54 F. Supp. 2d 788 (Kodrick v. Ferguson) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kodrick v. Ferguson, 54 F. Supp. 2d 788, 1999 U.S. Dist. LEXIS 1806, 1999 WL 98020 (N.D. Ill. 1999).

Opinion

MEMORANDUM AND ORDER

MORAN, Senior District Judge.

Plaintiff Lynn Kodrick (Kodrick) has filed a two-count claim against Cheryl Ferguson (Ferguson) and Ferguson’s former employer Accubanc Mortgage (Accubanc) seeking damages under the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq. The complaint charges, inter alia, that Accubanc was negligent in complying *789 with the FCRA when it did not prevent Ferguson from using Accubanc facilities to obtain Kodrick’s credit report under false pretenses. For the purpose of deciding Accubanc’s motion to dismiss the plaintiffs well-pleaded allegations are accepted as true, as are all reasonable inferences therefrom. Dawson v. General Motors, 977 F.2d 369, 372 (7th Cir.1992). The motion may be granted only where it appears beyond doubt that the plaintiff can prove no set of facts in support of her claim which would entitle her to relief. Conley v. Gibson, 355 U.S. 41, 45-46, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957). Even so, because we do not believe Accubanc can be held liable under the FCRA for Ferguson’s actions, we grant the motion to dismiss counts I and II as against Accubanc.

Background

As a senior loan officer at Accubanc, Ferguson was authorized to obtain and review the confidential credit histories of Accubanc’s customers. On two occasions in 1997, Ferguson used that authority to obtain a copy of plaintiffs credit report, ostensibly to process a real estate loan. Kodriek, however, had not applied for any loan, nor did she have any business relationship with Accubanc whatsoever. In fact, the real reason Ferguson wanted the information is that Kodriek is now married to Ferguson’s ex-husband.

Both parties acknowledge that Ferguson acted without the express approval of her supervisors at Accubanc. There is also no suggestion in the pleadings that liability must be imputed to Accubanc because Ferguson’s high rank makes her Accu-banc’s alter ego. See Burlington Industries, Inc. v. Ellerth, 524 U.S. 742, -, 118 S.Ct. 2257, 2267, 141 L.Ed.2d 633 (1998) (discussing § 219(2)(a) of the Restatement (2d) of Agency (1957)). Instead, plaintiff argues that Accubanc is liable because its negligence allowed “its authorized agent and officer to use its facilities to obtain credit reports under false pretenses” (plf s mem. in opp. at 2) To determine whether this allegation is sufficient to state a claim under the Fair Credit Reporting Act, we must review both the text and the purpose of the statute.

a. Fair Credit Reporting Act

The Fair Credit Reporting Act was passed in 1968 as Title VI of the Consumer Credit Protection Act. Pub.L.No. 90-321, Title VI, § 602, codified as amended by Pub.L.No. 91-508, Title VI, § 601, 84 Stat. 1128 (1970) at 15 U.S.C. § 1681 et seq. It was designed to “insure that consumer reporting agencies exercise their grave responsibilities with fairness, impartiality, and a respect for the consumer’s right to privacy.” 15 U.S.C. § 1681(a). Section 1681(b) further provides that

[i]t is the purpose of this subchapter to require that consumer reporting agencies adopt reasonable procedures for meeting the needs of commerce for consumer credit, personnel, insurance, and other information in a manner which is fair and equitable to the consumer, with regard to the confidentiality, accuracy, relevancy, and proper utilization of such information in accordance with the requirements of this subchapter.

The principle vehicle for accomplishing this goal was the enumeration of permissible circumstances under which consumer reporting agencies (CRAs) could furnish confidential consumer reports. Section § 1681b(a) contains the exclusive list of permissible purposes, including employment prescreening, § 1681b(a)(3)(B); responses to a court order, § 1681b(a)(l); compliance with the written instructions of the consumer, § 1681b(a)(2); and where the user has a “legitimate business need in connection with a business transaction that is initiated by the consumer,” § 1681b(a)(3)(F)(i). Litigation under this section has focused on the credit agency’s knowledge as to whether the requesting party sought the information for permissible purposes. See, e.g., Heath v. Credit Bureau of Sheridan, *790 Inc., 618 F.2d 693, 696 (10th Cir.1980) (finding that judicial inquiry into credit reporting agency motives was necessary component of § 1681b analysis, and holding that union member stated claim for relief against credit bureau on theory that it had delivered consumer report knowing that union had requested report for the impermissible purpose of humiliating its member). The FCRA also created civil liability for both negligent and willful violations of the Act, § 1681n-o, and provided a criminal penalty not to exceed $5000, one-year imprisonment, or both, for persons who obtain consumer information under false pretenses, § 1681q.

Notwithstanding these initial restrictions, rapidly evolving computer technology and an explosion in available consumer credit over the past two decades contributed to what one member of Congress referred to as an “Orwellian nightmare of erroneous and unknowingly disseminated credit reports” (140 Cong. Rec. H9797-05, H9810 (statement of Rep. Kennedy)). Thus, after much congressional debate and input from both consumer advocates and the credit industry, Congress passed the Consumer Credit Reporting Reform Act of 1996 (Reform Act) “to improve both the accuracy and privacy of consumer reports” {id.; Title II, Subtitle D, Chapter 1, of the Omnibus Consolidated Appropriations Act for Fiscal Year 1997, Pub.L.No.104-208, 110 Stat. 3009-426 (enacted Sept. 30, 1996; effective Sept. 30, 1997), codified as amended at 15 U.S.C. § 1681 et seq). The Reform Act gives the FTC expanded civil' enforcement authority over credit bureaus and information providers, regulates when CRAs may charge consumers a fee for credit reports, and expands the required disclosures to consumers when they are denied credit or employment based on a third party’s report. The maximum sentence under the criminal provision was increased to two years, a new civil liability provision was created for those who obtain a report under false pretenses, and an attorney’s fee provision was included to deter the filing of frivolous lawsuits.

In addition to strengthening the penalty provisions, the amendments also changed the language of the existing civil liability provisions, replacing “[a]ny consumer reporting agency or user of information which is negligent in failing to comply with any requirement” with “[a]ny

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Bluebook (online)
54 F. Supp. 2d 788, 1999 U.S. Dist. LEXIS 1806, 1999 WL 98020, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kodrick-v-ferguson-ilnd-1999.