In Delglyn v. Equifax (2019AP232), the Court of Appeals District I dismissed the plaintiff’s claims that Equifax violated the federal Fair Credit Reporting Act (FCRA) in its responses to the plaintiff’s notices of disputed items on his credit report.

Plaintiff James Delglyn sent a notice of dispute to Equifax regarding four accounts on his credit report. The entity running each of the four accounts responded and verified Delglyn’s accounts, and Equifax informed Delglyn of the results. Delglyn filed two more notices of dispute to Equifax regarding some of the accounts. Equifax reinvestigated those accounts and informed Delglyn accordingly.

Delglyn filed the instant complaint against Equifax, alleging that he had been denied a loan based on the Equifax reports, which he claimed failed to comply with the FCRA.

The FCRA provides that credit reporting agencies like Equifax must follow “reasonable procedures” to ensure accuracy. If a consumer notifies the agency of a dispute, the agency must conduct a “reasonable investigation.” Consumers like Delglyn alleging violations of the FCRA must establish that there was inaccurate information on their credit report because the agency did not follow “reasonable procedures” and that the inaccuracy caused damages.

The court found that Equifax did conduct a “reasonable investigation” into the accuracy of Delglyn’s accounts. Since the entities running the accounts verified the information with Equifax, Delglyn could not demonstrate that there was inaccurate information on his credit report. Therefore, Delglyn did not suffer damages due to an inaccuracy caused by Equifax, so his claims were dismissed.