Mayo v. Experian Information Solutions Inc

CourtDistrict Court, W.D. Washington
DecidedJanuary 20, 2023
Docket3:22-cv-05164
StatusUnknown

This text of Mayo v. Experian Information Solutions Inc (Mayo v. Experian Information Solutions Inc) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mayo v. Experian Information Solutions Inc, (W.D. Wash. 2023).

Opinion

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5 6 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT TACOMA 9 HOWARD MAYO, CASE NO. 3:22-cv-05164-DGE 10 Plaintiff, ORDER GRANTING 11 v. DEFENDANT’S MOTION FOR JUDGMENT ON THE PLEADINGS 12 EXPERIAN INFORMATION SOLUTIONS, 13 Defendant. 14 15 I INTRODUCTION 16 This matter comes before the Court on Defendant Experian Information Solutions, Inc.’s 17 Motion for Judgment on the Pleadings. (Dkt. No. 24.) Plaintiff Howard Mayo opposed 18 Defendant’s motion1 and Defendant replied.2 (Dkt. Nos. 28, 36.) For the reasons stated herein, 19 the Court GRANTS judgment on the pleadings in favor of Defendant. 20

21 1 Plaintiff requests oral argument. (Dkt. No. 38 at 1.) The Court finds that oral argument would not be helpful to the Court’s disposition of this motion and denies Plaintiff’s request. See LCR 22 7(b)(4).

23 2 Plaintiff filed a surreply. (Dkt. No. 38.) Under Local Civil Rule 7(g), a surreply shall not exceed three pages and can be filed for the limited purpose of “request[ing] to strike material contained in 24 1 II BACKGROUND 2 Plaintiff sues under the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. § 1681 et seq. 3 (Dkt. No. 1-4 at 10.) Beginning November 5, 2019, Plaintiff alleges Defendant inaccurately 4 reported his Bank of Missouri Visa credit card as a closed account. (Id.) Plaintiff alleges

5 Defendant listed inaccurate information on 40 credit reports all of which were dated between 6 November 5, 2019 and October 26, 2020.3 (Id.) Defendant corrected Plaintiff’s Bank of 7 Missouri account on November 20, 2020. (Id. at 57.) 8 During this period, Plaintiff disputed the status of his account nine times on November 5, 9 2019, November 22, 2019, December 11, 2019, February 27, 2020, March 12, 2020, March 19, 10 2020, April 14, 2020, July 12, 2020, and August 20, 2020.4 (Id. at 59.) Plaintiff alleges 11 Experian forwarded Automated Dispute Verification Code (ADVC) forms to the Bank of 12 Missouri for each of Plaintiff’s disputes. (Id. at 32.) In response, the Bank allegedly “report[ed] 13 Plaintiff’s credit card account open and reported the status of the account ‘current.’” (Id. at 18.) 14 Plaintiff further alleges Experian should have known the account was open because Experian’s

15 16 or attached to a reply brief.” “Extraneous argument or a surreply filed for any other reason will 17 not be considered.” LCR 7(g)(2). Plaintiff’s surreply is 21 pages and does not request to strike any material. Because Plaintiff’s surreply does not comply with the Local Civil Rules, the Court 18 does not consider it.

3 Plaintiff’s credit reports were dated November 5, 2019, November 8, 2019, November 22, 2019, 19 November 24, 2019, December 11, 2019, February 6, 2020, February 9, 2020, February 18, 2020, February 21, 2020, February 27, 2020, March 3, 2020, March 12, 2020, March 19, 2020, March 20 20, 2020, March 31, 2020, April 2, 2020, April 6, 2020, April 14, 2020, April 26, 2020, May 1, 2020, May 3, 2020, May 18, 2020, May 24, 2020, June 1, 2020, June 3, 2020, June 25, 2020, July 21 12, 2020, July 21, 2020, July 29, 2020, August 9, 2020, August 20, 2020, August 21, 2020, September 2, 2020, September 17, 2020, September 19, 2020, September 20, 2020, October 2, 22 2020, October 21, 2020, October 24, 2020, and October 26, 2020. (Dkt. No. 1-4 at 56.) 23 4 In Plaintiff’s proposed Second Amended Complaint, he does not allege he submitted a dispute on July 12, 2020. (Dkt. No. 27 at 68.) 24 1 “credit reports indicate[d] credit card usage on a reported[ly] ‘closed’ account” with various 2 percentages used, fluctuating balances, and a credit limit increase. (Id. at 17.) 3 Defendant’s inaccurate reporting allegedly caused Plaintiff to lose over three years5 of 4 on-time credit card payment history on an open account (id. at 41) and an artificially lowered

5 credit score of 610 (id. at 50). As a result, Plaintiff, a Vietnam veteran, was denied the 6 opportunity to apply for a Veteran’s Home Mortgage Loan, because the application requires a 7 minimum credit score of 620. (Id. at 50, 62.) Plaintiff also alleges he suffered because the 8 inaccurate report decreased the average age of all of Plaintiff’s credit accounts, worsened his 9 credit utilization ratio, and caused a loss of credit expectancy, worthiness, opportunity, 10 reputation, and capacity. (Id. at 37, 39–42.) Defendant disseminated inaccurate credit reports to 11 third parties, allegedly causing Plaintiff to be denied a Capital One Inc. Mastercard credit card on 12 February 1, 2020 and requiring him to bear a higher interest rate on his Fortiva Mastercard on 13 June 4, 2020. (Id. at 51.) Plaintiff suffered emotional distress and mental anguish as he 14 repeatedly tried to correct Defendant’s error. (Id. at 47.)

15 On August 4, 2020, Plaintiff sued Defendant in the Small Claims Department of the 16 District Court for Grays Harbor County.6 (Dkt. No. 24-1 at 2.) Plaintiff alleged Defendant 17 willfully failed to conduct reasonable reinvestigations of his disputes and to follow reasonable 18 procedures to assure maximum possible accuracy of reports in violation of FCRA 15 U.S.C. 19

20 5 The length of on-time credit card payment history Plaintiff accrued on his Bank of Missouri account is unclear from the Amended Complaint. Plaintiff alleges it was one year (Dkt. No. 1-4 21 at 6) but also alleges three years and eleven months (id. at 41). Because the Court views the facts in the light most favorable to Plaintiff, it assumes a history of over three years. 22 6 Defendant asks the Court to take judicial notice of the Small Claims Complaint and Judgment in Howard Mayo v. Experian Info. Solutions, Inc., Case No. C-13582 (Grays Harbor Small Claims 23 Dep’t., Aug. 4, 2020) (Dkt. No. 24-1 at 2–3, 5–7). (Dkt. No. 25 at 1.) The Court takes judicial notice of these court filings under Federal Rule of Evidence 201. See infra Section III, A. 24 1 § 1681(a)(1)(A) and 15 U.S.C. § 1681(e)(b). (Id. at 3.) Plaintiff presented evidence related to 2 four of his disputes. (Id.) Plaintiff also claimed Defendant disseminated his credit report which 3 caused Capital One Mastercard to deny him a credit card on February 1, 2020 and Credit One 4 Mastercard to deny increasing his credit limit on April 24, 2020.7 (Id.)

5 On December 29, 2020, the Small Claims Court issued a “Decision on Small Claims” in 6 Defendant’s favor, holding “[i]t appears to the Court that the actions of Bank of Missouri were at 7 fault for a wrong listing of the [inaccurate] status of the plaintiff at their Institution[.]” (Id. at 6.) 8 On February 16, 2022, Plaintiff brought this action in the Superior Court of Washington for 9 Grays Harbor County. (Dkt. No. 1-1 at 2.) On March 17, 2022, Defendant removed Plaintiff’s 10 Amended Complaint (Dkt. No. 1-4 at 1–62) to this Court. (See Dkt. No. 1.) Plaintiff seeks a 11 total of $343,000 in damages. (Dkt. No. 1-4 at 6.) 12 III DISCUSSION 13 A. Legal Standard for Judgment on the Pleadings 14 “After the pleadings are closed—but early enough not to delay trial—a party may move

15 for judgment on the pleadings.” Fed. R. Civ. P. 12(c). “Judgment on the pleadings is properly 16 granted when there is no issue of material fact in dispute, and the moving party is entitled to 17 judgment as a matter of law.” Fleming v. Pickard, 581 F.3d 922, 925 (9th Cir. 2009).

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Mayo v. Experian Information Solutions Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mayo-v-experian-information-solutions-inc-wawd-2023.