Paul v. EXPERIAN INFORMATION SOLUTIONS, INC., 2011 U.S. Dist. LEXIS 68292

Paul disputed a late-payment entry on a U.S. Bank account reported by Experian in 2008.
Paul had opened multiple U.S. Bank accounts in early 2007 and later closed many; one account reportedly had a remaining balance.
A U.S. Bank branch employee later told Paul the accounts were current and closed, though one balance remained unnotified.
A May 2008 letter from a U.S. Bank branch manager stated the negative reporting was an error and should be removed; Paul disputed with Experian on May 30, 2008.
Experian sent an Automatic Consumer Dispute Verification (ACDV) to U.S. Bank and later updated Paul’s report to reflect the bank’s responses, including a note about the Laliberte letter.
Paul filed suit in May 2009 alleging willful and negligent FCRA violations; the court granted summary judgment for Experian.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Experian followed reasonable procedures under 1681e(b).	Paul contends Experian failed to ensure accuracy by mishandling Laliberte letter.	Experian properly summarized and directed Bank investigation; no failure to follow reasonable procedures.	Experian did not fail; summary judgment for Experian on 1681e(b).
Whether Paul proved any inaccurate information causing harm under 1681e(b).	Paul argues the information was inaccurate or misleading.	Information was technically accurate; mislabeling due to bank error is insufficient to prove inaccuracy.	No causation or injury shown; 1681e(b) fails.
Whether the information was so misleading as to be inaccurate under 1681e(b).	Misleading depiction could render it inaccurate.	Account status stated as paid, but overdue details were accurate; not misleading enough.	Not enough to prove inaccuracy; 1681e(b) fails.
Whether Paul satisfied the elements of 1681i(a) reinvestigation claim.	CRAs must conduct a thorough reinvestigation including all relevant information.	CPAs should rely on furnisher information; CRA need not forward every document.	Paul failed to show inaccurate information or inadequate reinvestigation; 1681i(a) fails.
Whether forwarding Laliberte's letter was required to satisfy 1681i(a)(2)(A).	Experian should have forwarded all relevant documents to the furnisher.	ACDV and summarization suffice; forwarding is not mandated.	No obligation to forward the letter; summary satisfied 1681i(a)(2)(A).

Hauser v. Equifax, Inc., 602 F.2d 811 (8th Cir. 1979) (mere inaccuracy is not liability; must show failure to follow procedures to ensure accuracy)
Reed v. Experian Info. Solutions, Inc., 321 F. Supp. 2d 1109 (D. Minn. 2004) (CRA duty to reinvestigate; must show inaccuracies)
Gohman v. Equifax Info. Servs., LLC, 395 F. Supp. 2d 822 (D. Minn. 2005) (showing of inaccurate information required to state a § 1681e(b) claim)
DeAndrade v. Trans Union LLC, 523 F.3d 61 (1st Cir. 2008) (without inaccuracy, § 1681i claim fails)
Kuehling v. Trans Union, LLC, 137 F. App'x 904 (7th Cir. 2005) (inaccuracy element essential for § 1681i claims)
Edeh v. Midland Credit Mgmt., Inc., 748 F. Supp. 2d 1030 (D. Minn. 2010) (inaccuracy essential element for furnisher claims under § 1681s-2)