Michael Ritz v. Equifax Information Services LLC, 23-2181

Plaintiffs Andrew and Michael Ritz leased a vehicle that was ultimately serviced by Nissan Motor Acceptance Corporation under the same lease terms.
Plaintiffs attempted to return the vehicle at lease end but were refused by the dealership due to not having a scheduled return appointment, leaving the vehicle regardless.
Nissan continued to charge Plaintiffs for non-return, reported a delinquency to credit reporting agencies (CRAs), and refused to remove it due to a typo in the VIN on the return documentation.
Nissan’s customer service determined the Plaintiffs should owe nothing and requested removal of the delinquency, but the credit department did not act on this due to the VIN error.
Plaintiffs disputed the delinquency with both Nissan and CRAs; after various complaints, Nissan eventually removed the delinquency.
The district court granted summary judgment to Nissan, finding the dispute was contractual, not a factual inaccuracy actionable under the FCRA; Plaintiffs appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nissan reported inaccurate/incomplete info under FCRA	Nissan reported a debt Plaintiffs did not actually owe, as decided by its own complaints team	The reporting was accurate because the vehicle wasn't properly returned with required paperwork	There is a genuine dispute of material fact—summary judgment was improper
Whether FCRA requires investigation into legal disputes	Furnishers must investigate anything factually or materially inaccurate, even if rooted in contract disputes	FCRA only covers factual inaccuracy, not contract (legal) disputes	Court declined to resolve if legal disputes are covered; found fact issue present
Was Nissan's investigation into the dispute reasonable	It was unreasonable to ignore evidence from customer service and dealership due to a minor typo	Nissan's procedures require matching VIN, and reliance on typo meant info could not be verified	Reasonableness is for a jury—adequate evidence for a verdict for Plaintiffs
Whether summary judgment was appropriate	Disputed facts exist and should go to a jury	No genuine dispute; only a legal question	Summary judgment reversed; remanded for further proceedings

Bibbs v. Trans Union LLC, 43 F.4th 331 (3d Cir. 2022) (explaining prerequisites for reasonableness of CRA reinvestigation under the FCRA)
Seamans v. Temple Univ., 744 F.3d 853 (3d Cir. 2014) (defining "inaccuracy" under the FCRA, including materially misleading impressions)
Wharton v. Danberg, 854 F.3d 234 (3d Cir. 2017) (outlining standards for appellate review of summary judgment)
Giles v. Kearney, 571 F.3d 318 (3d Cir. 2009) (requiring facts to be viewed in favor of the nonmovant on summary judgment)
Cortez v. Trans Union, LLC, 617 F.3d 688 (3d Cir. 2010) (FCRA’s purpose to avoid inaccurate credit reporting)