Childress v. Experian Information Solutions, Inc.

Dist. Ct. did not err in granting defendant-consumer credit-reporting agency’s motion for summary judgment in action by plaintiff, alleging that defendant’s failure to initially indicate on plaintiff’s credit report that plaintiff’s dismissal of her Chapter 13 bankruptcy petition was via plaintiff’s motion to withdraw violated Fair Credit Reporting Act, since, according to plaintiff, her credit report did not accurately describe status of her bankruptcy petition. Record showed that when plaintiff’s bankruptcy petition was withdrawn, no documentation certifying said withdrawal had been submitted to defendant, and defendant was not required to conduct its own research into underlying reasons for dismissal of plaintiff’s bankruptcy petition. Ct. further noted that since every bankruptcy case that is “withdrawn” at debtor’s request is technically “dismissed,” defendant did not inaccurately indicate status of plaintiff’s bankruptcy petition.