Lea Johnson v. Freedom Mortgage Corp.
Split Score
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Case Summary
Disposition
Affirmed
Borrowers Lea and Samantha Johnson alleged that Freedom Mortgage violated the Fair Credit Reporting Act (FCRA) by reporting their mortgage payment as late and conducting only a cursory investigation after they disputed the report. The Eighth Circuit held that the late-payment information was accurate, Freedom Mortgage’s investigation was reasonable given the limited dispute notice it received, and therefore affirmed summary judgment for Freedom Mortgage.
Circuit Split Identified
Legal Issue
Whether § 1681s-2(b) of the FCRA imposes a heightened ‘materially misleading’ accuracy standard on furnishers (requiring them to avoid technically accurate yet misleading credit information) or only a ‘technical accuracy’ standard.
Circuit Positions
Heightened accuracy standard—information is inaccurate if it is materially misleading even when technically correct.
Undecided / has not adopted heightened standard; applies or assumes technical-accuracy rule unless and until a different standard is chosen.
Conflict Summary
The Fourth and Ninth Circuits treat a credit report as ‘inaccurate’ if technically correct information is presented in a way that could mislead a reasonable creditor, while the Eighth Circuit has expressly declined to adopt that heightened test and remains undecided, implicitly applying only the technical-accuracy approach until it chooses otherwise.