In October, the Sixth Circuit affirmed the dismissal of a claim for violating the Fair Credit Reporting Act (FCRA) by accessing a credit report without a permissible purpose in Daniel v. Goodyear Tire/CBSD. Such purposes include using the credit information in connection with a credit application involving a consumer or reviewing or collecting an account. Daniel brought claims for willful and negligent violation of the FCRA after she learned that the defendant card issuer had requested her credit report in June 2012, even though she allegedly never applied for credit, employment or insurance. The Court of Appeals ruled against the plaintiff because she did not contact the business until 16 months later, when the credit issuer no longer had record of her name.
