Michael Boyd v. Experian Information Solutions, Inc.
692 F. App'x 980
| 11th Cir. | 2017Background
- In Oct. 2007 an unknown party opened a Wells Fargo credit card in Michael Boyd’s name; Boyd first learned of it in Jan. 2008 after returning from sea. The account became over 60 days delinquent.
- Boyd disputed the account with Wells Fargo; the bank investigated and concluded Boyd was liable. The delinquency remained on his credit reports and allegedly harmed his security clearance and credit access.
- In Sept. 2014 Boyd again disputed the account with Equifax; Equifax forwarded the dispute to Wells Fargo, which again verified Boyd’s liability. The account remained on Boyd’s report until it aged off in Dec. 2014.
- Boyd sued Wells Fargo (Jan. 2015), alleging violations of the Fair Credit Reporting Act (15 U.S.C. § 1681s-2(b)) for an unreasonable reinvestigation and Georgia defamation for false reporting. He sought substantial actual and punitive damages.
- The district court granted summary judgment to Wells Fargo on the FCRA claim (finding Wells Fargo reasonably investigated and alternatively that Boyd produced no damages evidence) and dismissed the defamation claim for failure to plead malice. The Eleventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Wells Fargo unreasonably investigated Boyd’s 2014 dispute under FCRA § 1681s‑2(b) | Wells Fargo’s reinvestigation was inadequate and raised a genuine factual dispute | Wells Fargo conducted a reasonable investigation and verified the account; summary judgment appropriate | Affirmed for Wells Fargo (court also relied on alternative ground) |
| Whether Boyd proved damages from any FCRA violation | Boyd alleged credit harm, security‑clearance issues, and monetary loss totaling $200,000 | Wells Fargo argued Boyd presented no admissible evidence of damages causally linked to any FCRA violation | Summary judgment affirmed because Boyd failed to challenge district court’s alternative finding of no damages |
| Whether Boyd’s complaint adequately pleaded Georgia defamation | Complaint intended to allege defamation from false reporting | Wells Fargo argued complaint lacked required allegations (malice) under Georgia law | Dismissal affirmed for failure to plead malice; Twombly/Iqbal pleading standard applied |
| Whether appellate court may overturn when district court relied on independent grounds | N/A | N/A (applicable precedent limits reversal unless all grounds shown incorrect) | Court declined to reverse because appellant did not challenge every independent ground (Sapuppo) |
Key Cases Cited
- Byars v. Coca-Cola Co., 517 F.3d 1256 (11th Cir. 2008) (standard of review for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S. 1986) (summary judgment framework)
- Hill v. White, 321 F.3d 1334 (11th Cir. 2003) (standard for reviewing 12(b)(6) dismissal)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard)
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (conclusory allegations insufficient to plead claim)
- Krutzig v. Pulte Home Corp., 602 F.3d 1231 (11th Cir. 2010) (appellate affirmation on any grounds supported by record)
- Sapuppo v. Allstate Floridian Ins. Co., 739 F.3d 678 (11th Cir. 2014) (appellant must challenge all independent grounds for reversal)
- Info. Sys. & Networks Corp. v. City of Atlanta, 281 F.3d 1220 (11th Cir. 2002) (elements of defamation under Georgia law)