No Injury, No Standing: Gaudreau v. Trans Union

Who has the right to bring FCRA and related claims for credit reporting abuses? What if the plaintiff dies? Can a spouse join in the suit for damages?
David A. Szwak

No Injury, No Standing: Gaudreau v. Trans Union

Postby David A. Szwak » Fri Dec 09, 2005 12:40 pm

Not Reported in F.Supp.2d, 2001 WL 936122 (N.D.Ill.)

United States District Court, N.D. Illinois, Eastern Division.
Raymond J. GAUDREAU, Plaintiff,
TRANS UNION, Defendant.
No. 00 C 50356.
Aug. 17, 2001.

In fact, the court documents supplied to this court support the existence of the three federal tax liens and bankruptcy which appear on Gaudreau's credit report. (Def.Exhs.C-G) Gaudreau has produced nothing contesting the accuracy of the credit report. Thus, the court finds Trans Union's credit report is accurate. This leads to the next, and final, step of the analysis. Because the credit report is accurate, Gaudreau has not suffered any injury and, therefore, has no standing to sue under the FCRA. See Crabill v. Trans Union, LLC, No. 00-2078, ___ F.3d ___, 2001 WL 856573, at *2-3 (7 th Cir. July 30, 2001) (without a causal relationship between a violation of the FCRA and the loss of credit, plaintiff did not suffer any injury, resulting in a lack of standing under Article III); see generally Vermont Agency of Natural Res. v. United States, 529 U.S. 765, 771 (2000) (plaintiff must meet three requirements to establish Article III standing, one of which is injury in fact).

Gaudreau v. Trans Union
Not Reported in F.Supp.2d, 2001 WL 936122 (N.D.Ill.)

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