Department of Agriculture Rural Development Rural Housing Service v. Kirtz, 601 U.S. 42

Reginald Kirtz received and repaid a loan from USDA's Rural Housing Service but alleges the agency wrongly reported the loan as past due to a credit reporting agency (TransUnion), harming his credit.
Kirtz notified both TransUnion and the USDA of the alleged error, but the USDA did not investigate or correct the information.
Kirtz sued the USDA for damages under the Fair Credit Reporting Act (FCRA), which allows consumers to sue any “person”—a term defined to include government agencies—who willfully or negligently supplies false information to credit reporting agencies.
The USDA moved to dismiss, invoking sovereign immunity (the federal government's general immunity from damages suits unless Congress clearly waives it).
The District Court sided with USDA, but the Third Circuit reversed, holding the FCRA clearly authorizes such suits against federal agencies.
The Supreme Court granted certiorari to resolve a circuit split over whether the FCRA waives federal sovereign immunity for damages claims like Kirtz's.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the FCRA waive federal sovereign immunity for damages suits by consumers?	Yes—FCRA defines “person” to include government agencies, authorizes suit against “any person.”	No—statute does not clearly waive immunity or refer to it directly.	Yes—the FCRA clearly waives sovereign immunity for such suits.
Must waiver of immunity appear in a distinct provision, not just cause of action/definition linkage?	No—clear waiver can be read from cross-referenced definitions and liability provisions.	Yes—waiver requires explicit statutory text addressing immunity.	No—waiver can result from express incorporation of definitions.
Would application of the FCRA definition of “person” to agencies lead to absurd/invalid results?	No—Congress intended broad coverage, and holding agencies liable promotes FCRA goals.	Yes—includes states, possibly violating constitutional limits.	No—clear terms control; constitutional issues addressed separately.
Should legislative history or comparison to Privacy Act override FCRA’s plain text?	No—the statutory text is unambiguous and controls outcome.	Yes—overlap with Privacy Act means no need for dual remedies.	No—courts must enforce clear text even if remedies are duplicative.

United States v. Testan, 424 U.S. 392 (sovereign immunity bars damages suits unless Congress waives it)
Kimel v. Florida Bd. of Regents, 528 U.S. 62 (waiver can be found in cross-referenced definitions and liability provisions; clear statement rule)
Atascadero State Hospital v. Scanlon, 473 U.S. 234 (Congress must specifically mention government to waive immunity)
Seminole Tribe of Florida v. Florida, 517 U.S. 44 (statutory clarity on immunity distinct from its constitutional validity)
Sturgeon v. Frost, 587 U.S. 28 (courts must respect Congressional definitions absent true absurdity)