WALTON v. MONTGOMERY COUNTY COMMUNITY COLLEGE, 2:24-cv-06420

Zhari J. Walton sued Montgomery County Community College, alleging violations of the Fair Credit Reporting Act (FCRA), the Fair Debt Collection Practices Act (FDCPA), and state law breach of contract.
Walton claimed the College inaccurately reported a debt on his credit report and failed to provide adequate validation after multiple disputes.
He sought over $5 million in damages, including amounts for alleged credit denials, personal losses, and punitive damages.
Walton proceeded pro se and moved to proceed in forma pauperis (without paying filing fees).
The Court granted in forma pauperis status but screened the complaint for plausibility under 28 U.S.C. § 1915(e)(2)(B)(ii).
The Court reviewed federal question and diversity jurisdiction for the claims, given the mix of federal and state law issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
FCRA claim against College as furnisher	College reported incorrect debt and failed to validate	No formal defense stated, but is a furnisher only	Dismissed without prejudice—no plausible claim as alleged
College liable under FDCPA	College engaged in abusive or unauthorized debt collection	College is a creditor, not a debt collector	Dismissed with prejudice—College not a debt collector
State law breach of contract claim	College's actions breached an agreement	No formal defense stated	Dismissed for lack of federal jurisdiction
In forma pauperis screening	Sought to proceed without paying fees	N/A	Granted

Ashcroft v. Iqbal, 556 U.S. 662 (complaint must state plausible claim for relief)
Safeco Ins. Co. of Am. v. Burr, 551 U.S. 47 (FCRA is intended to ensure fair and accurate credit reporting)
SimmsParris v. Countrywide Fin. Corp., 652 F.3d 355 (FCRA protects consumers from inaccurate reporting)
Riccio v. Sentry Credit, Inc., 954 F.3d 582 (FDCPA applies to third-party debt collectors)
Henson v. Santander Consumer USA Inc., 137 S. Ct. 1718 (FDCPA distinguishes between debt owners and third-party collectors)