Vaiano v. Equifax Inc.

CourtDistrict Court, D. Massachusetts
DecidedFebruary 27, 2025
Docket1:24-cv-11332
StatusUnknown

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

Bluebook
Vaiano v. Equifax Inc., (D. Mass. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS ____________________________________ ) VINCENT VAIANO, ) ) Plaintiff, ) ) ) Civil Action No. 24-CV-11332-AK v. ) ) EQUIFAX, INC., ) JOHN DOES 1 THROUGH 5, ) JANE DOES 6 THROUGH 10, ) ) Defendants. ) )

MEMORANDUM AND ORDER ON MOTION TO DISMISS

A. KELLEY, D.J. Plaintiff Vincent Vaiano (“Vaiano”) filed this suit against Equifax, Inc. (“Equifax”) and several other unknown individuals who work for Equifax, alleging statutory and common-law claims because of information included in his credit report, as well as general claims regarding Equifax’s role in the credit reporting industry. For the following reasons, Equifax’s Motion to Dismiss for Failure to State a Claim [Dkt. 12] is GRANTED and this matter is DISMISSED WITH PREJUDICE. I. BACKGROUND In his Complaint, Vaiano makes several claims regarding Equifax and the credit reporting industry at large. He argues that the credit reporting industry is collusive, harming consumers and borrowers, while offering little benefit. Vaiano goes on to claim that the credit reporting industry shares little information about their decision-making processes and considerations, which has a large impact on everyday consumers’ credit reports, and operates in a way that makes it nearly impossible for victims of the industry to challenge the impact of different actions on their credit reports. As to Vaiano specifically, he alleges that he contracted COVID-19 in 2021, which caused him to be late on payments to his credit accounts. As a result, his credit score was lowered. Vaiano claims that the lowering of his score, as well as the lack of information provided about

how Vaiano’s score would be impacted, the lack of care of the company, and the lack of concern of its employees for his well-being, had distressing consequences on his life. In light of these allegations, Vaiano made a total of 19 claims, including: violations of the Fair Credit Reporting Act (“FCRA”) 15 U.S.C. § 1681 et seq., the Massachusetts Fair Credit Reporting Act (“MFCRA”), the Federal Fair Debt Collection Practices Act (“FDCPA”), Massachusetts’ Unfair Debt Collection Practices (“MDCPA”), negligent misrepresentation, false or misleading representations under 15 U.S.C. § 1125(a) and state law, fraudulent concealment, invasion of privacy, intentional and negligent infliction of emotional distress (“IIED” and “NIED”, respectively), defamation, libel, slander, negligent hiring, negligent failure to provide adequate

training, negligent failure to provide adequate supervision, tortious interference with an advantageous relationship, and violation of Massachusetts General Laws Ch. 93A. In its Motion to Dismiss, Equifax moves to dismiss all 19 claims on several alternative theories. As a final note, Vaiano has filed at least 10 identical or similar lawsuits throughout 2024. An identical complaint was filed by another litigant, who claims to have an address identical to Vaiano’s, on the same day that Vaiano filed the instant case. Brown v. Equifax Inc., No. 24-CV- 11331-LTS (D. Mass. Sept 27, 2024). Brown’s complaint was dismissed after he failed to file an opposition to the motion to dismiss. Id. [Dkt. 18]. Additionally, Vaiano filed an identical complaint on his own behalf against Trans Union. Vaiano v. Trans Union LLC et al., No. 24-CV- 11294-MJJ (D. Mass Feb. 11, 2025). That case was dismissed in full, after briefing of Trans Union’s motion to dismiss. Id. [Dkt. 18]. II. LEGAL STANDARD To survive a motion to dismiss under Federal Rule of Civil Procedure 12(b)(6), a

complaint must allege sufficient facts to state a claim for relief that is “plausible on its face” and actionable as a matter of law. Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). Reading the complaint “as a whole,” the Court must conduct a two-step, context-specific inquiry. García-Catalán v. United States, 734 F.3d 100, 103 (1st Cir. 2013). First, the Court must perform a close reading of the complaint to distinguish factual allegations from conclusory legal statements. Id. Factual allegations must be accepted as true, while legal conclusions are not entitled to credit. Id. A court may not disregard properly pleaded factual allegations even if actual proof of those facts is improbable. Ocasio- Hernández v. Fortuño-Burset, 640 F.3d 1, 12 (1st Cir. 2011). Second, the Court must determine

whether the factual allegations present a “reasonable inference that the defendant is liable for the misconduct alleged.” Haley v. City of Boston, 657 F.3d 39, 46 (1st Cir. 2011) (citation omitted). Dismissal is appropriate when the complaint fails to allege a “plausible entitlement to relief.” Rodriguez-Ortiz v. Margo Caribe, Inc., 490 F.3d 92, 95 (1st Cir. 2007) (quoting Twombly, 550 U.S. 544 at 559). Complaints brought by pro se litigants, as is the case with this action, are subjected to a lesser scrutiny than that of complaints drafted by attorneys. Ferranti v. Moran, 618 F.2d 888, 890 (1st Cir. 1980). Courts may “intuit the correct cause of action, even if [the complaint] was imperfectly pled,” provided the complaint contains sufficient facts to do so. Ahmed v. Rosenblatt, 118 F.3d 886, 890 (1st Cir. 1997). However, while pro se litigants are afforded more latitude in this realm, this latitude “cannot be taken to mean that pro se complaints are held to no standard at all.” Sergentakis v. Channell, 272 F. Supp. 3d 221, 224-25 (D. Mass. 2017) (internal quotation marks and citation omitted). In other words, “pro se status does not insulate a party from complying with procedural and substantive law.” Ahmed, 118 F.3d at 890.

III. DISCUSSION Although this Court liberally construes Vaiano’s pleadings because he is proceeding pro se, see Haines v. Kerner, 404 U.S. 519, 520-21 (1972), this action is subject to dismissal because the Complaint does not “comply[] with procedural and substantive law.” Ahmed, 118 F.3d at 890. The Complaint includes essentially no facts to support Vaiano’s claims. Id. (“The policy behind affording pro se plaintiffs liberal interpretation is that if they present sufficient facts, the court may intuit the correct cause of action, even if it was imperfectly pled. This is distinct from the case at hand, in which the formal elements of the claim were stated without the requisite supporting facts”). Each count is addressed in turn below.

A. Counts I and II (FCRA and MFCRA) Counts I and II are dismissed because Vaiano has not plausibly alleged that any reported information was inaccurate, let alone any facts to explain what reports or accounts were inaccurate or why. DeAndrade v. Trans Union LLC, 523 F.3d 61, 66-68 (1st Cir. 2008) (finding that to prevail on a claim under the FCRA, plaintiff must allege an inaccuracy in reporting).

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Vaiano v. Equifax Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/vaiano-v-equifax-inc-mad-2025.