Patterson v. Wells Fargo & Company

CourtCourt of Appeals for the Ninth Circuit
DecidedMay 18, 2026
Docket24-7439
StatusUnpublished

This text of Patterson v. Wells Fargo & Company (Patterson v. Wells Fargo & Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Patterson v. Wells Fargo & Company, (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAY 18 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

BERNARD J. PATTERSON; JOSHUA P. No. 24-7439 ADAMS; LINDA G. JORDAN, Individually and On Behalf of All Others D.C. No. Similarly Situated, 3:23-cv-03858-TLT Plaintiffs - Appellants, MEMORANDUM* v.

WELLS FARGO & COMPANY; WELLS FARGO BANK, N.A.,

Defendants - Appellees.

Appeal from the United States District Court for the Northern District of California Trina L. Thompson, District Judge, Presiding

Argued and Submitted April 20, 2026 San Francisco, California

Before: S.R. THOMAS, CHRISTEN, and FORREST, Circuit Judges; Partial Concurrence and Partial Dissent by Judge Forrest.

Plaintiffs Bernard Patterson, Joshua Adams, and Linda Jordan, on behalf of

a class of similarly situated individuals, appeal the district court’s order granting

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. Wells Fargo’s motion to dismiss pursuant to Federal Rule of Civil Procedure

12(b)(6).1 We have jurisdiction pursuant to 28 U.S.C. § 1291 and review the

district court’s decision de novo. Eichenberger v. ESPN, Inc., 876 F.3d 979, 982

(9th Cir. 2017). We affirm in part, reverse in part, and remand.

1. Plaintiffs adequately alleged that Wells Fargo violated the Fair Credit

Reporting Act (FCRA) by obtaining Plaintiffs’ credit reports without a permissible

purpose. See 15 U.S.C. § 1681b(f).2 To allege a violation of § 1681b(f), a plaintiff

must allege facts giving rise to a plausible inference that the defendant obtained the

plaintiff’s credit report without a permissible purpose. Nayab v. Cap. One Bank

(USA), N.A., 942 F.3d 480, 495–96 (9th Cir. 2019). The defendant bears “the

burden of pleading it had an authorized purpose.” Id. at 495.

Here, Plaintiffs alleged that they had no existing business relationship with

Wells Fargo, that they did not apply for Wells Fargo bank accounts, and that Wells

Fargo opened bank accounts in their names. Plaintiffs further alleged that before

opening these accounts, Wells Fargo received Plaintiffs’ true and correct personal

1 Because the parties are familiar with the facts, we do not recount them here. 2 Plaintiffs raise claims pursuant to both FCRA and the California Consumer Credit Reporting Agencies Act (CCRAA). The parties agree that Plaintiffs’ arguments concerning FCRA apply with equal force to the CCRAA, a statute that is “substantially based on [FCRA].” Carvalho v. Equifax Info. Servs., LLC, 629 F.3d 876, 889 (9th Cir. 2010) (citation modified). Compare 15 U.S.C. § 1681b(f), with Cal. Civ. Code § 1785.19(a)(1)–(2).

2 24-7439 identification information (PII) from an identity verification service, and that for

some of Plaintiffs, this PII contradicted the PII Wells Fargo associated with the

unauthorized accounts.3 After opening the bank accounts in Plaintiffs’ names,

Wells Fargo obtained each of Plaintiffs’ credit reports. Plaintiffs’ allegations—

accepted as true and construed in the light most favorable to Plaintiffs,

Eichenberger, 876 F.3d at 981—give rise “to a reasonable inference that [Wells

Fargo] obtained [their] credit report[s] for a purpose not authorized by statute.”

Nayab, 942 F.3d at 499. The allegations “rule out many of the potential authorized

purposes for obtaining a credit report,” and “together with [Plaintiffs’] allegation

that [Wells Fargo], in fact, obtained [their] report[s], state a plausible claim for

relief.” Id. at 496–97.

2. Plaintiffs’ allegations support an inference that Wells Fargo’s violation of

FCRA was willful. See 15 U.S.C. § 1681n(a). To allege a willful violation of the

“knowing” variety, a plaintiff must allege that a defendant “knowing[ly]

disregard[ed]” its FCRA obligations. See Moran v. Screening Pros, LLC, 25 F.4th

722, 728–29 (9th Cir. 2022).4 Here, the operative complaint supports the inference

3 The operative complaint alleges that Wells Fargo received true and correct PII for each plaintiff and that this PII contradicted the PII associated with the Patterson and Adams accounts. But the operative complaint does not explain what PII Wells Fargo associated with the account opened in Jordan’s name. 4 Plaintiffs expressly disclaim any reliance on the “reckless” variety of willful violations. Moran, 25 F.4th at 728.

3 24-7439 that Wells Fargo willfully violated FCRA by obtaining Plaintiffs’ credit reports

despite knowing that it had no colorable basis for doing so.

Wells Fargo insists, and the district court purported to find, that its actions

demonstrate it reasonably believed that Plaintiffs were its existing customers. But

even if the operative complaint compelled this inference, that alone would not

establish a permissible purpose. The statutory provision Wells Fargo relies upon,

§ 1681b(a)(3)(F)(i), permits access to a credit report where a user has a legitimate

business need “in connection with a business transaction that is initiated by the

consumer.” Id. (emphasis added). Similarly, the provision identified by the

district court, § 1681b(a)(3)(A), “can be relied upon by the party requesting a

credit report only if the consumer initiates the transaction.” Pintos v. Pac.

Creditors Ass’n, 605 F.3d 665, 675 (9th Cir. 2010) (emphasis added) (citation

modified). The operative complaint does not suggest that Plaintiffs initiated any

transaction with Wells Fargo, even if Wells Fargo believed they were its legitimate

customers.

Moreover, as to plaintiffs Patterson and Adams, the operative complaint

alleges that Wells Fargo knew or had reason to know that they did not apply for the

accounts Wells Fargo opened in their names. According to the complaint, the

correct PII Wells Fargo received from an identity verification service contradicted

the PII associated with the accounts. The complaint explains that despite knowing

4 24-7439 that Patterson and Adams may not have opened the accounts, Wells Fargo went on

to obtain their credit reports in knowing disregard of FCRA.

3. Plaintiffs fail to adequately allege that Wells Fargo negligently violated

FCRA because their allegations of actual damages are too conclusory. See

Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A plaintiff who shows that a

defendant “is negligent in failing to comply” with FCRA may recover only actual

damages. See 15 U.S.C. § 1681o(a).

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Pintos v. PACIFIC CREDITORS ASS'N
605 F.3d 665 (Ninth Circuit, 2010)
Chad Eichenberger v. Espn, Inc.
876 F.3d 979 (Ninth Circuit, 2017)
Freshta Nayab v. Capital One Bank (Usa), Na
942 F.3d 480 (Ninth Circuit, 2019)
Gabriel Moran v. the Screening Pros, LLC
25 F.4th 722 (Ninth Circuit, 2022)
Carvalho v. Equifax Information Services, LLC
629 F.3d 876 (Ninth Circuit, 2010)

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Patterson v. Wells Fargo & Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patterson-v-wells-fargo-company-ca9-2026.