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Practice

Consumer Reporting Agencies + Background Screening

We have extensive and industry-leading experience litigating consumer reporting and background screening cases under the Fair Credit Reporting Act (FCRA). We have served as counsel to consumer reporting agencies in more than 1,500 cases nationwide, including over 100 FCRA class actions and more than 35 background screening class actions, involving every provision of the FCRA related to the background screening process.

The background screening process is a critical component of modern hiring. Employers face potential liability both for failing to conduct background screenings and for issues arising from the screening process itself. Increased regulatory attention and an active litigation environment make maintaining compliance with the FCRA and related state background screening laws challenging. 

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Class Actions

  • Obtained summary judgment on behalf of a national background screening company in a putative class action alleging claims under 15 U.S.C. § 1681k(a) and 15 U.S.C. § 1681e(b). The court also ruled that the plaintiff lacked standing and denied the plaintiff’s motion for class certification.
  • Served as lead counsel for a nationwide tenant screening company in a proposed nationwide FCRA class action claim challenging the reporting of “race” information and outdated criminal histories. Obtained dismissal of the race reporting claim on First Amendment grounds and defeated class certification of the claim relating to the reporting of criminal histories.
  • Served as counsel for a national “wholesaler” of consumer data in a class action lawsuit asserted under 15 U.S.C. § 1681k(a) for allegedly using a consumer report for “employment purposes” without complying with the FCRA’s notice requirements, including whether the consumer report was, in fact, used for “employment purposes”.
  • Represented a Fortune 100 data aggregator relating to nationwide class action claims challenging the defendant’s background screening products, including the issue of whether such products were subject to the requirements of the FCRA.

Individual Actions

  • Defended a background screening company in a claim under 15 U.S.C. § 1681a(k)(1)(B)(ii) for allegedly taking “adverse action” against a prospective employee, including whether such action was indeed “adverse” under the FCRA.
  • Represented a background screening company in a lawsuit asserted under 15 U.S.C. § 1681e(b) for allegedly failing to establish or follow reasonable procedures to assure maximum possible accuracy in the preparation of the consumer reports.
  • Served as counsel for a background screening company for a claim under 15 U.S.C. § 1681i for allegedly failing to conduct a reasonable investigation in a timely manner (i.e., within 30 days of the date on which it received notice of the dispute from the consumer).
  • Filed an amicus brief to the U.S. Supreme Court on behalf of a national trade association of background screeners in an FCRA dispute involving cutting-edge Article III standing issues under the U.S. Constitution.

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