Professional Background Screening Association v. Philip J. Weiser, in his Official Capacity as Attorney General of the State of Colorado

CourtDistrict Court, D. Colorado
DecidedMarch 20, 2026
Docket1:25-cv-00295
StatusUnknown

This text of Professional Background Screening Association v. Philip J. Weiser, in his Official Capacity as Attorney General of the State of Colorado (Professional Background Screening Association v. Philip J. Weiser, in his Official Capacity as Attorney General of the State of Colorado) is published on Counsel Stack Legal Research, covering District Court, D. Colorado primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Professional Background Screening Association v. Philip J. Weiser, in his Official Capacity as Attorney General of the State of Colorado, (D. Colo. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Philip A. Brimmer

Civil Action No. 25-cv-00295-PAB-CYC

PROFESSIONAL BACKGROUND SCREENING ASSOCIATION,

Plaintiff,

v.

PHILIP J. WEISER, in his Official Capacity as Attorney General of the State of Colorado,

Defendant.

ORDER

This matter comes before the Court on the Motion to Dismiss Pursuant to Fed. R. Civ. P. 12(B)(1) [Docket No. 8]. Plaintiff filed a response, Docket No. 41, and defendant filed a reply. Docket No. 46. I. BACKGROUND1 Plaintiff Professional Background Screening Association (“PBSA”) is an international trade association of over 800 member companies that provide employment, insurance, and tenant background screening and related services. Docket No. 1 at 5, ¶ 15. PBSA filed this action on January 28, 2025, arguing that two provisions of the Colorado Consumer Credit Reporting Act (“CCRA”), Colo. Rev. Stat. § 5-18-101 et seq., are preempted by the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. § 1681 et seq. Id. at 9-10, ¶¶ 37-40. The FCRA governs all manner of consumer

1 The facts below are taken from plaintiff’s complaint, Docket No. 1, and are presumed to be true, unless otherwise noted, for purposes of ruling on defendant’s motion to dismiss. reports used for employment screening, tenant screening, insurance, and many other purposes. Id. at 6, ¶ 21. One area of consumer reporting which the FCRA addresses is what can and cannot be included in a consumer report. Id. at 7, ¶ 25. Specifically, the FCRA proscribes consumer reports from including, among other items, civil suits, civil judgments, or arrest records that antedate the report by more than seven years, and

any other adverse item of information other than records of convictions of crimes that antedate the report by more than seven years. Id., ¶ 28 (citing 15 U.S.C. §§ 1681c(a)(2), 1681c(a)(5)). The FCRA preempts state laws which are inconsistent with any provision of the FCRA, to the extent of the inconsistency. Id. at 8, ¶ 33 (citing 15 U.S.C. § 1681t(a)). Moreover, the FCRA states that “‘[n]o requirement or prohibition may be imposed under the laws of any State . . . with respect to any subject matter regulated under . . . section 1681c of this title, relating to information contained in consumer reports.’” Id. at 9, ¶ 35 (quoting 15 U.S.C. § 1681t(b)(1)(E)). Section 5-18-109 of the CCRA prohibits reporting “‘[r]ecords of arrest, indictment,

or conviction of a crime that, from the state of disposition, release, or parole, predate the report by more than seven years.’” Id., ¶ 37 (quoting Colo. Rev. Stat. § 5-18-109(1)(e)). Plaintiff argues that this conflicts with Congress’s decision not to prohibit the reporting of criminal conviction records in the FCRA. Id. at 10, ¶ 38. Moreover, on May 10, 2022, the Colorado legislature enacted the Clean Slate Act, which went into effect on August 31, 2022. Id., ¶ 39. The Clean Slate Act amended the CCRA to add subsection 5-18- 109(e.5), which prohibits reporting sealed records, expunged records, and records that did not result in a conviction. Id. (citing Colo. Rev. Stat. § 5-18-109(e.5)). Plaintiff argues that this conflicts with Congress’s decision not to make the FCRA prohibit the reporting of criminal non-conviction records which do not antedate the report by more than seven years. Id., ¶ 40. Plaintiff asserts that, “[u]pon information and belief, the Attorney General intends to use his authority to enforce Colo. Rev. Stat. Ann. § 5-18-109 to prohibit the reporting of the criminal conviction records or non-conviction records that PBSA’s members

currently report in compliance with the requirements of the FCRA.” Id., ¶ 42. In accordance with that belief, plaintiff brings suit against defendant Philip J. Weiser— Colorado’s attorney general—in his official capacity, seeking a declaratory judgment that Colo. Rev. Stat. § 5-18-109 is preempted by the FCRA and seeking injunctive relief prohibiting defendant from enforcing Colo. Rev. Stat. § 5-18-109. Id. at 15-19, ¶¶ 62- 82. On March 18, 2025, defendant filed a motion to dismiss under Fed. R. Civ. P. 12(b)(1). Docket No. 8. Briefing on the motion to dismiss was stayed pending argument on whether jurisdictional discovery should be allowed. Docket No. 19. The jurisdictional discovery was ultimately not allowed. Docket No. 38. On February 9,

2026, plaintiff filed a response. Docket No. 41. On March 2, 2026, defendant filed a reply. Docket No. 46. II. LEGAL STANDARD Federal Rule of Civil Procedure 12(b)(1) allows a party to move to dismiss a claim for lack of subject matter jurisdiction. Fed. R. Civ. P. 12(b)(1). A dismissal under Rule 12(b)(1) is not a judgment on the merits; rather, it is a determination that the court lacks jurisdiction to adjudicate the claim. Creek Red Nation, LLC v. Jeffco Midget Football Ass’n., Inc., 175 F. Supp. 3d 1290, 1293 (D. Colo. 2016). A court lacking jurisdiction “must dismiss the cause at any stage of the proceedings in which it becomes apparent that jurisdiction is lacking.” Caballero v. Fuerzas Armadas Revolucionarias de Colombia, 945 F.3d 1270, 1273 (10th Cir. 2019) (citation omitted). The dismissal is without prejudice. Brereton v. Bountiful City Corp., 434 F.3d 1213, 1218 (10th Cir. 2006). Challenges to subject matter jurisdiction may take two forms—a facial attack or a factual attack—each with distinct analytical frameworks. United States v. Rodriguez-

Aguirre, 264 F.3d 1195, 1203 (10th Cir. 2001). A facial challenge focuses on the sufficiency of the allegations in the complaint. Id. In resolving a facial challenge, “the district court must accept the allegations in the complaint as true.” Id. By contrast, a factual challenge allows a party to “go beyond allegations contained in the complaint and challenge the facts upon which subject matter jurisdiction depends.” Id. (citation omitted). In addressing a factual challenge to subject matter jurisdiction, “the court does not presume the truthfulness of the complaint’s factual allegations.” Id. (citation and quotations omitted); see also Stuart v. Colo. Interstate Gas Co., 271 F.3d 1221, 1225 (10th Cir. 2001) (“a court’s reference to evidence outside the pleadings does not convert

the motion into a Rule 56 motion”). The burden of establishing subject matter jurisdiction lies with the party asserting it. Merida Delgado v. Gonzales, 428 F.3d 916, 919 (10th Cir. 2005). Here, defendant asserts that he is raising a facial challenge, which characterization plaintiff does not dispute. Docket No. 8 at 4; Docket No. 41 at 12. III.

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Professional Background Screening Association v. Philip J. Weiser, in his Official Capacity as Attorney General of the State of Colorado, Counsel Stack Legal Research, https://law.counselstack.com/opinion/professional-background-screening-association-v-philip-j-weiser-in-his-cod-2026.