Giallela v. United Property Management, Inc., Civil Action No. 2023-1978

Plaintiff Rebecca Giallella, a resident of D.C., sued United Property Management (UPM), Equifax, and Experian for violations of the Fair Credit Reporting Act (FCRA) after an identity thief leased a Florida apartment in her name.
UPM, incorporated and headquartered in Florida, managed the Florida property, and reported Giallella’s lease as in default to credit agencies.
Giallella notified UPM of the fraudulent lease and submitted supporting documents but did not provide a police report as UPM requested.
After disputing the lease with Equifax, which was communicated to UPM, UPM allegedly misreported the lease as a mortgage and verified its accuracy to Equifax.
UPM moved to dismiss the case for lack of personal jurisdiction, improper venue, and failure to state a claim; Equifax and Experian answered the complaint.
The court considered only the personal jurisdiction issue, holding that UPM’s Florida-based conduct and lack of D.C. contacts did not establish jurisdiction in D.C.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal jurisdiction over UPM in D.C.	UPM’s FCRA violation caused her injury in D.C.; UPM knew she was a D.C. resident.	UPM is a Florida company with no D.C. contacts or business.	No personal jurisdiction in D.C.; D.C. law and due process not met.
Applicability of D.C. long-arm statute	UPM’s conduct targeted her in D.C., meeting the statute’s requirements.	UPM’s actions all occurred in Florida, with no persistent conduct in D.C.	Statute not satisfied; no "plus factors" connecting UPM to D.C.
Whether case should be dismissed or transferred	If no jurisdiction, transfer to S.D. Florida is appropriate.	Prefers dismissal, but acknowledges Florida as proper forum if transferred.	Sever and transfer claims against UPM to S.D. Florida; rest remain in D.C.
Basis for FCRA claim	UPM must investigate disputes reported by credit agencies and reported inaccurately.	No private right of action for direct consumer dispute; no liability.	UPM’s duty to investigate arises only via agency notification, not direct dispute.

Sinochem Int'l Co. v. Malaysia Int'l Shipping Co., 549 U.S. 422 (explains prerequisite of jurisdiction before merits)
Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 141 S. Ct. 1017 (specific vs. general jurisdiction distinction)
Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (defining "at home" for general jurisdiction)
Walden v. Fiore, 571 U.S. 277 (jurisdiction depends on defendant’s forum contacts, not just injury to plaintiff)
Calder v. Jones, 465 U.S. 783 (effects test for personal jurisdiction—requires defendant’s forum conduct)