Bibbs v. Trans Union LLC

Bibbs v. Trans Union LLC

Opinion

 [*571]  MEMORANDUM

KEARNEY, J.

Marissa Bibbs claims credit reporting agency Trans Union violates federal law by reporting both a zero-balance owed to student loan creditor Navient and a debt owed to Navient over 120 days past due when Navient transferred the debt and closed her account. She does not identify a loss or the denial of credit because of Trans Union's reporting. She instead argues it is impossible to both owe nothing to Navient when it transferred and closed her account and have a pay status of 120 days past due. Her argument makes some sense on first pass when looking at one entry on her credit report. But we must read the entire report mindful Congress does not require Trans [**2]  Union provide an encyclopedic explanation of her obligation to the creditor; a credit report instead offers a snapshot which must be accurate or not mislead a creditor based on the entirety of investigated and reported data. All parties concede Navient transferred her overdue debt on the date reported, closed her obligation, and reported her as paying 120 days past due. This is patently accurate. It is not misleading. We grant Trans Union's Motion for judgment on the pleadings and deny Ms. Bibbs's cross-Motion because Trans Union accurately represents her obligation as of the date Navient closed and transferred her debt.  [*572]  There is no dispute she owed nothing more to Navient upon transfer and her obligations had been 120 days past due at time of transfer. We grant her leave to timely amend if she can plead facts consistent with Rule 11 showing the credit report is patently inaccurate or misleading.

I. Alleged undisputed facts

Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.