Rodney Antonio Batts v. Capital One, Equifax Information Services LLC

CourtDistrict Court, S.D. Indiana
DecidedDecember 30, 2025
Docket1:25-cv-00410
StatusUnknown

This text of Rodney Antonio Batts v. Capital One, Equifax Information Services LLC (Rodney Antonio Batts v. Capital One, Equifax Information Services LLC) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Rodney Antonio Batts v. Capital One, Equifax Information Services LLC, (S.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

RODNEY ANTONIO BATTS, ) ) Plaintiff, ) ) v. ) No. 1:25-cv-00410-TWP-MKK ) CAPITAL ONE, ) EQUIFAX INFORMATION SERVICES LLC, ) ) Defendants. )

ORDER ON MOTIONS TO DISMISS AND OTHER PENDING MOTIONS

This matter is before the Court on Defendant Capital One's Motion to Dismiss Plaintiff's Amended Complaint (Dkt. 39), Equifax Information Services LLC's ("Equifax") Motion to Dismiss Plaintiff's Amended Complaint Pursuant to Fed. R. Civ. P. 12(B)(6) (Dkt. 41), (collectively, "Defendants"), and Equifax's Rule 56(d) Motion in Response to Plaintiff’s Motion for Summary Judgment (Dkt. 54). Also pending are several motions filed by pro se Plaintiff Rodney Antonio Batts ("Batts"), including an Objection to the Magistrate Judge's Order Denying Plaintiff's Motion for Revised Civil Cover Sheet and Motion to Amend Complaint ("Objection") (Dkt. 45), Plaintiff's Combined Motion for Writ of Mandamus and Summary Judgment (Dkt. 50), and four "Counter Motions" (Dkts. 43, 44, 47, 48) which the Court discerns to be responses to Defendants' motions to dismiss. In his Amended Complaint, Batts alleges the Defendants violated his rights under the Fair Credit Reporting Act 15 U.S.C. § 1681 ("FCRA") (Dkt. 26-1). For the reasons explained in this Order, Defendants Motions to Dismiss are denied, Equifax's Rule 56(d) Motion is granted, Batts' Objection is overruled, his combined Motion for Summary Judgment and Writ of Mandamus is denied, and all duplicitous filings are stricken. I. LEGAL STANDARD Federal Rule of Civil Procedure 12(b)(6) allows a defendant to move to dismiss a complaint that has failed to "state a claim upon which relief can be granted." Fed. R. Civ. P. 12(b)(6). When deciding a motion to dismiss under Rule 12(b)(6), the Court accepts as true all factual allegations in the complaint and draws all inferences in favor of the plaintiff. Bielanski v. Cty. of Kane, 550

F.3d 632, 633 (7th Cir. 2008). However, courts "are not obliged to accept as true legal conclusions or unsupported conclusions of fact." Hickey v. O'Bannon, 287 F.3d 656, 658 (7th Cir. 2002). The complaint must contain a "short and plain statement of the claim showing that the pleader is entitled to relief." Fed. R. Civ. P. 8(a)(2). In Bell Atlantic Corp. v. Twombly, the Supreme Court explained that the complaint must allege facts that are "enough to raise a right to relief above the speculative level." 550 U.S. 544, 555 (2007). Although "detailed factual allegations" are not required, mere "labels," "conclusions," or "formulaic recitation[s] of the elements of a cause of

action" are insufficient. Id.; see also Bissessur v. Ind. Univ. Bd. of Trs., 581 F.3d 599, 603 (7thCir. 2009) ("it is not enough to give a threadbare recitation of the elements of a claim without factual support"). The allegations must "give the defendant fair notice of what the . . . claim is and the grounds upon which it rests." Twombly, 550 U.S. at 555. Stated differently, the complaint must include "enough facts to state a claim to relief that is plausible on its face." Hecker v. Deere & Co., 556 F.3d 575, 580 (7th Cir. 2009) (citation modified). To be facially plausible, the complaint must allow "the court to draw the reasonable inference that the defendant is liable for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citing Twombly, 550 U.S. at 556). A document filed pro se is to be liberally construed, and a pro se complaint, however inartfully pleaded, must be held to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. Pardus, 551 U.S. 89, 94 (2007) (citations and quotation marks omitted). However, it is also well established that pro se litigants are not excused from compliance with procedural rules. Members v. Paige, 140 F.3d 699, 702 (7th Cir. 1998) (stating that procedural rules “apply to uncounseled litigants and must be enforced”).

II. BACKGROUND The Court accepts Batts' factual allegations in his Amended Complaint as true and draws all inferences in his favor as the non-moving party, but not his legal conclusions. See Bielanski, 550 F.3d at 633; See Iqbal, 556 U.S. at 678 ("[W]e must take all of the factual allegations in the complaint as true," but "we 'are not bound to accept as true a legal conclusion couched as a factual allegation.'") (quoting Twombly, 550 U.S. at 555). In October 2022, Batts attempted to open a line of credit with First Merchants Bank (Dkt. 26-1 at 7). The Amended Complaint alleges that in the forty-five-day waiting period after applying, Capital One and Equifax reported a thirty-day late payment for a credit card ending in 1307 for

the month of November 2022 to Batts' credit report. Id. Batts alleges the report was inaccurate and caused an inaccurate payment history. Id. ¶ 21. After the First Merchants Bank loan officer notified Batts that his credit score had decreased, Batts launched a dispute with Capital One, but Capital One said he needed to contact Equifax to correct the error. Id. at 7. When he contacted Equifax, Batts was told it was Capital One's responsibility to fix the error because Equifax reports the data that Capital One provides. Id. In December 2022, a second Equifax credit report still included the inaccuracies (Dkt. 26- 1 ¶¶ 42–43). Batts alleges that his credit score decreased sixty points due to the inaccurate reporting. Id. ¶ 44. He filed a complaint with the Better Business Bureau on February 14, 2023, and again on February 16, 2023, listing the inaccuracies that still existed on his credit report. Id.

Batts notified Capital One that they were reporting inaccurate information through a dispute letter on January 2, 2023, and he notified Equifax through a similar letter on March 1, 2023. Id. ¶¶ 46– 47. Batts alleges that Capital One is a data furnisher under the FCRA and that Equifax sent his disputes to Capital One. Id. ¶ 39. Despite knowledge of the issues, both Defendants continued to report inaccuracies associated with the account ending in 1307 and Batts' credit score remained at the decreased

number. Id. ¶ 49. After being notified of the inaccuracies, neither Defendant properly investigated the inaccuracies reported by Batts. Id. ¶ 50. Both Defendants "continually ignored" Batts for several months after he mailed the March 1, 2023 letter, causing him actual damages. Id. ¶ 48. Due to the inaccurate reporting and decreased credit score, Batts was denied credit, incurred out of pocket expenses, and suffered emotional harm, physical sickness, and excessive stress (Dkt. 26-1 at 17). Batts filed his original complaint on March 3, 2025 (Dkt. 1) and filed the operative Amended Complaint on May 15, 2025 (Dkt. 26-1).

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Rodney Antonio Batts v. Capital One, Equifax Information Services LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rodney-antonio-batts-v-capital-one-equifax-information-services-llc-insd-2025.