Michelle Trapp v. SunTrust Bank
699 F. App'x 144
| 4th Cir. | 2017Background
- Michelle and David Trapp applied for a loan from SunTrust Bank to purchase a boat; SunTrust denied the application.
- SunTrust told the Trapps the denial was due to issues with David Trapp’s Social Security number, which generated a high fraud score (linked to a deceased person).
- The Trapps sued under the Equal Credit Opportunity Act (ECOA), alleging SunTrust’s actions violated the statute.
- The district court granted SunTrust summary judgment, concluding the Trapps lacked standing.
- The Trapps appealed; the Fourth Circuit reviewed standing and summary judgment de novo.
- The Fourth Circuit affirmed the judgment but modified the dismissal to be without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standing — injury in fact under Article III | Trapps argued SunTrust’s ECOA violation (procedural) sufficed as injury; denial of required disclosure/information harmed them | SunTrust argued Trapps suffered no concrete informational injury because they knew SSN-linked problem, attempted remediation, and suffered no real-world loss (they bought the boat with cash) | Court held no concrete injury; alleged procedural ECOA violation alone did not meet Spokeo standard — no Article III standing |
| Causation/traceability to SunTrust conduct | Trapps tied denial to SunTrust’s use or disclosure of credit/fraud info | SunTrust maintained denial was based on SSN/fraud score tied to deceased-person linkage, not a disclosure injury | Court accepted that the denial traced to SSN/fraud linkage but found that did not create a cognizable informational injury |
| Redressability | Trapps contended a favorable ruling could remedy statutory violation | SunTrust argued no practical relief because no concrete harm occurred | Court found redressability irrelevant without injury; dismissed claim without prejudice |
| Remedy/relief following dismissal | Trapps sought judgment on merits and relief under ECOA | SunTrust sought final dismissal on jurisdictional grounds | Court affirmed dismissal for lack of standing but modified to without prejudice allowing potential refiling if concrete injury later shown |
Key Cases Cited
- Dreher v. Experian Info. Solutions, Inc., 856 F.3d 337 (4th Cir. 2017) (explaining informational-injury framework for standing)
- Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (requiring a concrete and particularized injury-in-fact for Article III standing)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requirements and injury-in-fact principles)
- Int’l Refugee Assistance Project v. Trump, 857 F.3d 554 (4th Cir. 2017) (noting that a statutory violation does not automatically satisfy Article III)
- S. Walk at Broadlands Homeowner’s Ass’n v. OpenBand at Broadlands, LLC, 713 F.3d 175 (4th Cir. 2013) (dismissal without prejudice principles)