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Catherine Taylor v. Tenant Tracker, Inc.

Citations: 710 F.3d 824; 2013 WL 1235314Docket: 11-3466

Court: Court of Appeals for the Eighth Circuit; March 28, 2013; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this case, the plaintiff, Catherine L. Taylor, brought a lawsuit against Tenant Tracker, Inc., alleging violations of the Fair Credit Reporting Act (FCRA) due to inaccuracies in a criminal background report generated by the defendant. The report erroneously included entries from another individual, 'Chantel Taylor,' leading to initial concerns during Taylor's application for federal housing assistance. However, the Housing Authority quickly resolved the issue and approved her application. The district court granted summary judgment in favor of Tenant Tracker, a decision upheld by the Eighth Circuit, on the grounds that Taylor failed to provide evidence of technical inaccuracies or negligence by Tenant Tracker. The court also addressed the FCRA's requirement for proving 'actual damages,' including emotional distress, and found Taylor's evidence insufficient to demonstrate 'genuine injury' as required by precedent. Despite Taylor's claims of emotional distress, the court noted the absence of physical injury, medical treatment, or corroborative testimony from witnesses. Consequently, the court concluded that Taylor did not meet the threshold for establishing actual damages under the FCRA, resulting in the dismissal of her claims.

Legal Issues Addressed

Actual Damages under FCRA

Application: The case evaluated the requirement for proving 'actual damages' under the FCRA, focusing on the necessity of demonstrating genuine injury from emotional distress claims.

Reasoning: Under the Fair Credit Reporting Act (FCRA), Taylor is entitled to recover 'actual damages' resulting from Tenant Tracker's negligent noncompliance, as defined in 15 U.S.C. 1681o(a)(1).

Emotional Distress as Actual Damages

Application: The court found that Taylor's emotional distress, which was not substantiated by credible evidence of genuine injury, was insufficient to support a claim for actual damages.

Reasoning: Taylor only reported emotional injury, with no adverse actions taken by the Housing Authority following the report.

Fair Credit Reporting Act (FCRA) Compliance

Application: The court assessed whether Tenant Tracker, Inc. adhered to reasonable procedures to ensure the accuracy of credit reporting data, as mandated by the FCRA.

Reasoning: Catherine L. Taylor sued Tenant Tracker, Inc., alleging violations of the Fair Credit Reporting Act (FCRA) due to the company's failure to implement reasonable procedures for ensuring the accuracy of its credit reporting.

Summary Judgment Standards

Application: The district court granted summary judgment for Tenant Tracker, which was affirmed on appeal, due to insufficient evidence of technical inaccuracy or negligence by Tenant Tracker.

Reasoning: The district court granted summary judgment in favor of Tenant Tracker, which was subsequently affirmed by the Eighth Circuit.