Brill v. TransUnion, LLC

Dist. Ct. did not err in dismissing plaintiff’s action under Fair Credit Reporting Act, alleging that defendant-credit reporting agency failed to conduct reasonable reinvestigation regarding plaintiff’s claim that his name had been forged on Toyota car lease, which, in turn, caused him to incur negative comment on his credit report. While plaintiff claimed that former girlfriend had forged his signature on lease, and that defendant should have done something more than asking Toyota to confirm accuracy of credit report by confirming that plaintiff’s name was on said lease, Dist. Ct. could properly find that defendant had no duty to verify accuracy of plaintiff’s signature, since Toyota was in better position to determine validity of its own lease. Ct. rejected plaintiff’s claim that reinvestigation was inadequate because defendant failed to either hire handwriting expert to determine validity of signature on lease or ask Toyota employees involved in lease extension to advise whether signature on original and extension leases were of same person. Also, plaintiff failed to include in record both original and extension leases so as to support his forgery claim.