Bryson v. TransUnion LLC
- David Doty
- 0:25-cv-01717
- U.S. District Court · District of Minnesota
- 5
In Bryson v. TransUnion LLC, Judge Doty granted the defendants' motions to dismiss and permanently closed the case after finding that plaintiff Brandon Bryson, representing himself, failed to plead any specific facts to support his claims that Trans Union, LLC and Transworld Systems, Inc. violated federal credit reporting and debt collection laws.
Individuals who represent themselves in federal court and bring claims under the Fair Credit Reporting Act or Fair Debt Collection Practices Act; this ruling illustrates that even pro se plaintiffs must allege specific facts — not just general accusations of harm — to keep their cases alive in federal court.
What happened
In Bryson v. TransUnion LLC, Brandon Bryson, representing himself, sued Trans Union, LLC and Transworld Systems, Inc. claiming they violated two federal consumer protection laws: the Fair Credit Reporting Act (FCRA), which governs how credit reporting agencies collect and report credit information, and the Fair Debt Collection Practices Act (FDCPA), which regulates how debt collectors behave. Bryson alleged that Trans Union reported inaccurate, outdated, and previously disputed accounts on his credit report, and that Transworld reported false or misleading debt information. He claimed these violations caused him serious harm, including being denied loans and credit, having his car repossessed, and being threatened with eviction.
To survive dismissal, Bryson needed to allege specific facts showing: (1) the defendants failed to follow reasonable procedures to ensure accurate reporting; (2) they actually reported inaccurate information about him; (3) he suffered harm; and (4) their failure caused that harm. The court found that beyond alleging harm, Bryson did not plead any of these required elements. He did not identify what specific information was inaccurate, when it was reported, or how the defendants' procedures were inadequate. The court also struck a second amended complaint Bryson filed without the required court permission, and noted that even if it had been considered, it still would not have met the legal standard.
Judge Doty granted both defendants' motions to dismiss and dismissed the entire case with prejudice, meaning Bryson cannot refile the same claims in this court. The judge noted that Bryson had submitted three complaints and several briefs, none of which came close to properly stating a legal claim, making a permanent dismissal appropriate.
The detailed version
In Bryson v. TransUnion LLC, Civil No. 25-1717 (DSD/DTS), United States District Judge David S. Doty of the District of Minnesota granted the motions to dismiss filed by defendants Trans Union, LLC and Transworld Systems, Inc., and dismissed the case with prejudice.
Background
Pro se (self-represented) plaintiff Brandon Bryson filed an amended complaint on May 8, 2025, alleging violations of the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681 et seq., and the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. § 1682 et seq. Bryson alleged that Trans Union reported 'inaccurate, re-aged, and previously disputed accounts' on his credit report, and that Transworld reported 'false or misleading information regarding debt allegedly owed, including outdated balances, misdated activity, and failure to verify debts upon dispute.' He named several accounts but did not explain how the information was inaccurate or when it was reported. He claimed defendants failed to correct the data despite his attempt to arbitrate, and alleged resulting psychological and emotional distress, denial of loans and credit, car repossession, and threatened eviction. He sought actual damages, statutory damages, punitive damages, and injunctive relief.
After Trans Union filed its motion to dismiss, Bryson filed a second amended complaint without seeking leave of court, in violation of Federal Rule of Civil Procedure 15(a)(2), which requires either the opposing party's written consent or court approval before filing an amended pleading past the initial amendment as of right. The court struck that filing from the docket and noted it would have failed pleading standards regardless.
Legal Standard
The court applied the pleading standard from Ashcroft v. Iqbal, 556 U.S. 662 (2009), and Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), requiring a complaint to contain sufficient factual matter, accepted as true, to state a claim for relief that is plausible on its face. Labels, conclusions, and formulaic recitations of elements are insufficient. Because Bryson is pro se, the court applied a liberal construction standard, meaning it interpreted his filings more generously than it would for a represented party.
Analysis
To state a claim under the FCRA, a plaintiff must allege that: (1) the defendant failed to follow reasonable procedures to assure accuracy; (2) the defendant reported inaccurate credit information; (3) the plaintiff suffered harm; and (4) the defendant's failure caused the harm. Citing Paul v. Experian Info. Services, Inc., 793 F. Supp. 2d 1098, 1101 (D. Minn. 2011), the court found that Bryson alleged only harm — the fourth element — and failed to plead any of the other required elements. He did not identify which specific information was inaccurate, when it was reported, or what procedures were inadequate.
Disposition
Judge Doty granted both motions to dismiss (ECF Nos. 21 and 31) and dismissed the case with prejudice — meaning Bryson may not refile these claims. The court cited the fact that Bryson had submitted three complaints and several briefs, none of which came close to properly stating a legal claim against either defendant, as justification for dismissal with prejudice rather than allowing further amendment. The second amended complaint (ECF No. 27) was stricken from the docket. Judgment was ordered to be entered accordingly.
Reviewer note from the AI+
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