Aldaco v. RentGrow, Inc.

Federal 7th Circuit Court
Civil Court
Fair Credit Reporting Act
Case Number: 
No. 18-1932
Decision Date: 
April 16, 2019
Federal District: 
N.D. Ill., E. Div.

Dist. Ct. did not err in granting defendant’s motion for summary judgment in plaintiff’s action alleging that defendant violated Fair Credit Reporting Act, when defendant reported to plaintiff’s prospective landlord that plaintiff had pleaded guilty to battery charge in 1996 and received six-month supervision sentence that caused landlord to reject plaintiff’s rental application. Act prohibits disclosure of any arrest record of over seven years, but allows agencies to report convictions no matter how old, and Ct. rejected plaintiff’s claim that her successful completion of her supervision sentence precluded defendant from reporting her battery conviction, even though under state law her battery charge was dismissed after her completion of her supervision sentence. Ct. further found that federal definition of conviction applied, and that plaintiff’s guilty plea and sentence of supervision qualified as conviction under federal law. As such, defendant did not violate Act when it reported plaintiff’s battery conviction to her prospective landlord.