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The District Court for the District of Nevada recently found that a plaintiff cannot bring a solely of the disclosure claim in federal court when he or she has suffered no actual harm separate from the perceived failure to properly format the disclosure. In Williams v. TLC Casino Enters, the plaintiff alleged that TLC Casino Enterprises violated the Fair Credit Reporting Act (FCRA) by obtaining a consumer report on her without providing her with a stand-alone document of a legal disclosure. The business moved to dismiss the complaint for lack of standing, arguing that the claim amounted to nothing more than a bare procedural violation of the FCRA. The court agreed with TLC Casino Enterprises.

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