Rodriguez v. U.S. Healthworks CA1/1, A168143

Background

In 2013, Catrina Rodriguez applied for employment with U.S. Healthworks, Inc. and electronically signed several forms authorizing a background check as part of her application process.
The offer letter explicitly stated that employment was contingent upon a satisfactory background and reference check, among other conditions.
Healthworks ordered and received Rodriguez’s background check before hiring her; she later acknowledged in a "New Associate Checklist" that preemployment screening had been completed.
Rodriguez’s employment ended in April 2016; she filed a class action lawsuit in October 2017, alleging violations under the Fair Credit Reporting Act (FCRA) due to deficient notice regarding the procurement of her consumer report.
The trial court granted summary judgment for Healthworks, finding Rodriguez’s claim barred by the FCRA’s two-year statute of limitations.
Case was remanded from federal to state court after the Ninth Circuit concluded Rodriguez lacked Article III standing in federal court.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
When did the FCRA statute of limitations begin to run?	Rodriguez argued she lacked constructive notice Healthworks obtained the consumer report, so the limitations period hadn't started.	Healthworks argued that Rodriguez had constructive notice via forms she signed and her employment contingent on a background check.	The court held that a reasonably diligent plaintiff would have known, triggering the statute of limitations by July 26, 2013.
What is required for FCRA statute of limitations discovery—is actual or constructive knowledge needed?	Rodriguez argued only actual knowledge triggers the statute of limitations.	Healthworks argued, and law provides, that constructive knowledge suffices.	The court held constructive knowledge was sufficient, rejecting actual knowledge as the standard.
Did Rodriguez receive adequate disclosure and acknowledgment of the background check?	Rodriguez argued forms and disclosures conflicted, and she never received the report, so no clear notice was given.	Healthworks argued Rodriguez consented and acknowledged preemployment screening completion.	The court held the forms and checklist established constructive notice of the background check.
Is the claim time-barred under FCRA’s two-year statute of limitations?	Rodriguez argued the clock never started, so claim was timely.	Healthworks argued claim was filed more than four years after constructive notice.	The court held the claim was barred by the two-year FCRA limitation period.

Key Cases Cited

Syed v. M-I, LLC, 853 F.3d 492 (9th Cir. 2017) (explains FCRA’s disclosure/authorization requirements and statute of limitations)
Merck & Co. v. Reynolds, 559 U.S. 633 (2010) (establishes standard for discovery-based statutes of limitations, including constructive discovery)
Drew v. Equifax Information Services, LLC, 690 F.3d 1100 (9th Cir. 2012) (applies constructive discovery rule to FCRA limitations period)
Johnson v. City of Loma Linda, 24 Cal. 4th 61 (2000) (sets standard for reviewing summary judgment decisions de novo)