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Context Matters: Court Grants Summary Judgment for Defendant and Emphasizes that Entire Tradeline Must be Analyzed in FCRA Claims | Troutman Pepper

In
Ellis v. Warehouse Home Furnishings Distribs., Judge Catherine M. Salinas, of the United States District Court for the Northern District of Georgia, granted summary judgment for Warehouse Home Furnishings Distributors, Inc., f/k/a Farmers Furniture Company (“Farmers”), holding that Ellis failed to raise a genuine issue of material fact as to whether “the Farmers tradeline on [Ellis’s] credit reports contained any inaccurate or incomplete information” or whether Ellis suffered damages regarding Ellis’s Fair Credit Reporting Act (“FCRA”) claim.
In 2013, Ellis obligated herself to making two hundred and fifteen-dollar monthly payments for twenty-four months under a Retail Installment Contract/Security Agreement with Farmers. Subsequently, Ellis obtained disability insurance that paid off Ellis’s loan by 2015. In 2018, two national credit reporting agencies prepared credit reports regarding Ellis’s Farmers tradeline listing the two hundred and fifteen-dollar monthly payment amounts, while also reflecting the balance on the account as zero dollars.

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