Plaintiff lacked standing to pursue his Fair Credit Reporting Act (FCRA) claim against defendant-bank, alleging that defendant had failed to investigate two credit reporting disputes regarding plaintiff’s loan payments. Plaintiff was required to show injury that was something more than statutory violation for purposes of Article III standing, and plaintiff’s alleged injury in form of lower credit score was not traceable to defendant’s alleged failure to investigate, where subject disputes arose from notices that were issued in January of 2012, while plaintiff’s alleged drop in credit score occurred in November of 2011. Also, Dist. Ct. could properly grant defendant’s summary judgment motion with respect to plaintiff’s breach of contract and breach of fiduciary claims, where plaintiff’s proffered evidence of his damages was only speculative.
Federal 7th Circuit Court
Civil Court
Fair Credit Reporting Act