Ali v. TransUnion Rental Screening Solutions, LLC, 0:25-cv-00583

Plaintiff Mohamed Ahmed Ali sued TransUnion Rental Screening Solutions, LLC under the Fair Credit Reporting Act for providing inaccurate tenant screening reports that included criminal records not attributable to him.
Ali’s rental application was denied after Pathlight Property Management received a report from TransUnion with these errors.
Discovery revealed additional incidents from November 2023: another inaccurate report and an incorrect inquiry listed in his consumer disclosure.
Ali moved to amend his complaint to add these new factual allegations, filing his motion within the court's scheduling deadline.
The litigation is still in the discovery phase, and the case is before the court on Ali's motion for leave to file his first amended complaint.
The magistrate judge considers whether to allow amendment under Rule 15’s liberal standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ali can amend to add new incidents	New facts are timely and relevant to FCRA	Amendment asserts mutually exclusive facts (timing)	Not mutually exclusive; leave to amend is granted
Relevance of November 26 inquiry	Shows TransUnion’s failure of procedures	Not actionable; no third-party disclosure occurred	Factual allegations may have procedural relevance
Rule 15 standard for amendment	Amendment is just, timely, and allowed	Amendment should be denied for the reasons above	Rule 15 favors amendment; none of the exceptions met

Foman v. Davis, 371 U.S. 178 (1962) (leave to amend should be freely given unless an exception applies)
Becker v. Univ. of Nebraska at Omaha, 191 F.3d 904 (8th Cir. 1999) (motions to amend should be denied only if clearly frivolous)
Reuter v. Jax Ltd., Inc., 711 F.3d 918 (8th Cir. 2013) (reciting the factors for denying leave to amend)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleadings standard under Rule 8(a))