Patrick v. LexisNexis Risk Solutions

CourtDistrict Court, D. Delaware
DecidedJuly 9, 2025
Docket1:23-cv-00827
StatusUnknown

This text of Patrick v. LexisNexis Risk Solutions (Patrick v. LexisNexis Risk Solutions) is published on Counsel Stack Legal Research, covering District Court, D. Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patrick v. LexisNexis Risk Solutions, (D. Del. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE BRIANA PATRICK, ) Plaintiff, v. Civil Action No. 23-827-GBW LEXISNEXIS RISK SOLUTIONS, Defendant.

Briana Patrick, Wilmington, Delaware — Pro se Plaintiff Richard Montgomery Donaldson, MONTGOMERY MCCRACKEN WALKER & RHOADS LLP, Wilmington, Delaware — Counsel for Defendant LexisNexis Risk Solutions MEMORANDUM OPINION

July 9, 2025 Wilmington, Delaware

WILLIAMS, U.S. District Judge: I. INTRODUCTION On August 1, 2023, Plaintiff Briana Patrick, of Wilmington, Delaware, initiated this civil action by filing a complaint pro se. (D.I. 2.) Defendant LexisNexis Risk Solutions now moves to dismiss the complaint for failure to state a claim. (D.I. 9.) Additionally, Plaintiff moves for summary judgment. (D.I. 16.) Defendant’s motion to dismiss will be granted, and Plaintiff's motion for summary judgment will be denied. Il. BACKGROUND According to the complaint, Defendant violated Plaintiff's rights under the Fair Credit Reporting Act (FCRA) in Wilmington, Delaware, between April 1, 2023, and May 21, 2023. (D.I. 2 at 3-4.) The alleged FCRA violations caused an increase in Plaintiffs car insurance rate from $343.67 to $405.00, which Plaintiff was unable

to afford, resulting in cancellation of the policy, extreme stress, and reputational harm. (/d. at 5, 7.) Plaintiff now seeks $30,000 and “removal of all personal information from [Defendant’s] records and database.” (/d.) First, the complaint alleges that Defendant “furnish[ed| a driving and loss history and prior insurance report on [Plaintiff's] behalf,’ without Plaintiffs “written consent or instruction to furnish a report,” which Plaintiff believes violated “15 U.S.C. [§] 1681b(2).” Ud. at 4-5.)

Second, the complaint alleges that Defendant “failed to conduct an initial investigation prior to furnishing two claims and two insurance transactions on [Plaintiff's] consumer report.” (Ud. at 5.) Plaintiff “did not give [Defendant] permission to access [Plaintiffs] personal information,” and Plaintiff did not “get the opportunity to communicate that [she] did not want the [above described] information furnished.” (/d.) Plaintiff believes that the Defendant breached Plaintiff's privacy by “accessing [her] non-public personal information.” (/d. at 7.) Plaintiff believes that Defendant’s failure “to conduct a re[a]sonable investigation once notified of the unauthorized information,” and Defendant’s failure “to remove and block” this information, violated 15 U.S.C. § 16811(5)(A). (/d. at 5.) Il. LEGAL STANDARDS In reviewing a motion to dismiss filed under Fed. R. Civ. P. 12(b)(6), the Court must accept all factual allegations in a complaint as true and take them in the light most favorable to Plaintiff. See Erickson v. Pardus, 551 U.S. 89, 94 (2007). Because Plaintiff proceeds pro se, her pleading is liberally construed and her Complaint, “however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson, 551 U.S. at 94. A Rule 12(b)(6) motion may be granted only if, accepting the well-pleaded allegations in the complaint as true and viewing them in the light most favorable to the complainant, a court concludes that those allegations “could not raise a claim of

entitlement to relief.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 558 (2007). “Though ‘detailed factual allegations’ are not required, a complaint must do more than simply provide ‘labels and conclusions’ or ‘a formulaic recitation of the elements of a cause of action.’” Davis v. Abington Mem’l Hosp., 765 F.3d 236, 241 (3d Cir. 2014) (quoting Twombly, 550 U.S. at 555). The Court is “not required to credit bald assertions or legal conclusions improperly alleged in the complaint.” In re Rockefeller Ctr. Props., Inc. Sec. Litig., 311 F.3d 198, 216 (3d Cir. 2002). A complaint may not be dismissed, however, “for imperfect statement of the legal theory supporting the claim asserted.” Johnson v. City of Shelby, 574 U.S. 10, 11 (2014). Courts faced with a motion to dismiss pursuant to Rule 12(b)(6) must generally limit their consideration to “the allegations contained in the complaint,

_ exhibits attached to the complaint and matters of public record.” Pension Benefit Guar. Corp. v. White Consol. Indus., Inc., 998 F.2d 1192, 1196 (3d Cir. 1993). A complainant must plead facts sufficient to show that a claim has “substantive plausibility.” Jd. at 12. That plausibility must be found on the face of the complaint. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). “A claim has facial plausibility when the [complainant] pleads factual content that allows the court to draw the reasonable inference that the [accused] is liable for the misconduct alleged.” Jd. Deciding

whether a claim is plausible will be a “context-specific task that requires the reviewing court to draw on its judicial experience and common sense.” Id. at 679.

IV. DISCUSSION The complaint fails to state a claim pursuant to 15 U.S.C. § 1681b. It is unclear from the complaint whether Plaintiff intends to allege that Defendant violated subsection (a)(2) or (b)(2) of § 1681b; either way, the complaint fails to

state a claim. While subsection (a)(2) permits a consumer reporting agency to furnish a

consumer report “[i]Jn accordance with the written instructions of the consumer to whom it relates,” subsection (a)(3) sets out other permissible purposes absent

consumer consent, such as furnishing a report “in connection with the underwriting of insurance,” or in connection with a current insurer’s valuation of “an existing credit obligation,” and “to determine whether the consumer continues to meet the

terms of the account.” Compare 15 U.S.C. § 1681b(a)(2), with id. § 1681b(a)(3)(C), (E), (F)Gi). Additionally, subsection (b)(2) sets out consumer disclosure requirements for reporting agencies, but these requirements only apply when a report is furnished “for employment purposes.” See id. § 1681b(b)(2)(A). The complaint does not allege that Defendant furnished Plaintiff's consumer

report for employment purposes; the report was allegedly used by an insurance

company to calculate Plaintiff's car insurance rate, which subsection a(3) permits without consumer consent. As such, the complaint does not plausibly state that Defendant furnished a consumer report for an impermissible purpose, or in an impermissible manner, under § 1681b. The complaint also fails to state a claim pursuant to 15 U.S.C. § 16811(5)(A). While subsection (5)(A) sets out requirements for the treatment of inaccurate or unverifiable information, the complaint does not sufficiently allege that any information Defendant furnished to Plaintiff's insurance company was inaccurate, incomplete, or unverifiable.

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Related

Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
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311 F.3d 198 (Third Circuit, 2002)
Collette Davis v. Abington Mem Hosp
765 F.3d 236 (Third Circuit, 2014)

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Patrick v. LexisNexis Risk Solutions, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patrick-v-lexisnexis-risk-solutions-ded-2025.