Olivas v. Trans Union, LLC

CourtDistrict Court, E.D. California
DecidedOctober 22, 2024
Docket2:22-cv-01243
StatusUnknown

This text of Olivas v. Trans Union, LLC (Olivas v. Trans Union, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Olivas v. Trans Union, LLC, (E.D. Cal. 2024).

Opinion

8 UNITED STATES DISTRICT COURT

9 FOR THE EASTERN DISTRICT OF CALIFORNIA

11 RAUL OLIVAS, No. 2:22-cv-01243-DJC-CKD

12 Plaintiff, v. 13 ORDER GOLDER 1 CU, et al., 14 Defendants. 15

17 Defendant Trans Union, LLC (“Trans Union”) moves for judgment on the

18 pleadings as to Plaintiff Raul Olivas’s claims that they are inaccurately reporting the

19 pay status of a closed mortgage account on his credit report as currently “60 Days Past

20 Due.” Trans Union argues their reporting is accurate as a matter of law because the

21 account was 60 days past due at the time it was closed in December 2018, and the

22 report reflects tha t this was the historical, not current, pay status. 23 Having considered the Parties’ briefing and arguments, the Court agrees with 24 Trans Union, and will GRANT judgment in Trans Union’s favor on Plaintiff’s claims. 25 BACKGROUND 26 In 2018, Plaintiff had a mortgage account (“Account”) serviced by Golden 1 27 Credit Union. (Compl. (ECF No. 1-3) ¶ 5.) In December 2018, the Account was paid in 28 full and closed with a $0 balance. (Id. ¶¶ 6–7.) At the time the Account was closed, it 1 was reporting as 60 days past due. (Id. ¶ 8.) Plaintiff alleges that, “[d]espite the debt

2 being paid in full, Golden 1 has been reporting to TransUnion and Equifax that

3 Plaintiff’s payment status is currently late by greater than 60 days throughout 2020 and

4 2021.” (Id.)

5 On or about October 2020, Plaintiff sent a dispute letter to Trans Union

6 disputing the pay status on the Account. (Id. ¶ 12.) In response, Trans Union notified

7 Golden 1 Credit Union, who advised Trans Union to continue reporting the pay status

8 of the Account as 60 days past due. (Id. ¶¶ 13–14.) Trans Union has continued to do

9 so. (Id. ¶ 15; see also Roberts Decl. (ECF No. 19-2), Ex. A.)

10 Based on these allegations, Plaintiff claims that Trans Union negligently and

11 willfully violated the Fair Credit Reporting Act (“FCRA”) by failing to ensure the

12 accuracy of the information it reported under 15 U.S.C. § 1681e(b), and by failing to

13 conduct a reasonable investigation once Plaintiff brought inaccuracies to its attention

14 under 15 U.S.C. § 1681i. (Compl. ¶¶ 29–35.) Plaintiff also claims Trans Union violated

15 California’s corollary to the FRCA, the Consumer Credit Reporting Agencies Act

16 (“CCRAA”), Cal. Civ. Code §1785.1 et seq. (Id. ¶¶ 51–56.)

17 Trans Union brought this Motion for Judgment on the Pleadings on July 24,

18 2024, seeking dismissal of all claims against them. (Mot. J. Pleadings (ECF No. 19).)

19 The Court held a hearing on October 3, 2024, with Robert Sibilia appearing for

20 Plaintiff, and Jason Roberts appearing for Trans Union. The Court took the matter

21 under submission.

22 LEGAL STANDARD

23 Rule 12(c) of the Federal Rules of Civil Procedure provides that “[a]fter the

24 pleadings are closed—but early enough not to delay trial—a party may move for

25 judgment on the pleadings.” Fed. R. Civ. P. 12(c). The same legal standard applicable 26 to a Rule 12(b)(6) motion applies to a Rule 12(c) motion. Dworkin v. Hustler Mag., Inc., 27 867 F.2d 1188, 1192 (9th Cir. 1989). Accordingly, the allegations of the non-moving 28 party must be accepted as true, while any allegations made by the moving party that 1 have been denied or contradicted are assumed to be false. MacDonald v. Grace

2 Church Seattle, 457 F.3d 1079, 1081 (9th Cir. 2006). The facts are viewed in the light

3 most favorable to the non-moving party and all reasonable inferences are drawn in

4 favor of that party. Living Designs, Inc. v. E.I. DuPont de Nemours & Co., 431 F.3d 353,

5 360 (9th Cir. 2005). “[J]udgment on the pleadings is properly granted when, taking all

6 the allegations in the non-moving party’s pleadings as true, the moving party is

7 entitled to judgment as a matter of law.” Marshall Naify Revocable Tr. v. United States,

8 672 F.3d 620, 623 (9th Cir. 2012) (quoting Fajardo v. County of Los Angeles, 179 F.3d

9 698, 699 (9th Cir. 1999)).

10 If the Court “goes beyond the pleadings to resolve an issue,” a judgment on the

11 pleadings is not appropriate and “such a proceeding must properly be treated as a

12 motion for summary judgment.” Hal Roach Studios, Inc. v. Richard Feiner & Co., 896

13 F.2d 1542, 1550 (9th Cir. 1989); Fed. R. Civ. P. 12(d). However, a district court may

14 “consider certain materials—documents attached to the complaint, documents

15 incorporated by reference in the complaint, or matters of judicial notice—without

16 converting the motion . . . into a motion for summary judgment.” United States v.

17 Ritchie, 342 F.3d 903, 908 (9th Cir. 2003). Courts have discretion in appropriate cases

18 to grant a Rule 12(c) motion with leave to amend, or to simply grant dismissal of the

19 action instead of entry of judgment. See Lonberg v. City of Riverside, 300 F. Supp. 2d

20 942, 945 (C.D. Cal. 2004).

21 DISCUSSION

22 The FCRA was enacted in order to ensure fair and accurate credit reporting.

23 Shaw v. Experian Info. Sols. Inc., 891 F.3d 749, 755 (9th Cir. 2018). To assert a claim

24 under sections 1681e(b) or 1681i of the FCRA—alleging either that a consumer credit

25 report is inaccurate or that a credit reporting agency did not conduct a proper 26 reinvestigation to determine whether the disputed information is inaccurate—a plaintiff 27 must plead the existence of a factual inaccuracy within their report. See Guimond v. 28 Trans Union Credit Info. Co., 45 F.3d 1329, 1333 (9th Cir. 1995); Carvalho v. Equifax 1 Info. Servs., LLC, 629 F.3d 876, 890 (9th Cir. 2010). Information in a credit report is

2 inaccurate if it is “patently incorrect, or because it is misleading in such a way and to

3 such an extent that it can be expected to adversely affect credit decisions.” Carvalho,

4 629 at 890–91. “[I]nformation is only materially misleading when it is ‘open to an

5 interpretation that is directly contradictory to the true information.’” Sanchez v.

6 JPMorgan Chase Bank NA, 643 F. Supp. 3d 1025, 1033 (D. Ariz. 2022) (quoting Gross

7 v. Private Nat’l Mortg. Acceptance Co., LLC, 512 F. Supp. 3d 423, 427 (E.D.N.Y. 2021)).

8 Similarly, inaccuracy is a required element for a CCRAA claim as the statutory

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