On March 14th, 2025, the United States Court of Appeals for the Fourth Circuit issued a decision in the case of Roberts v. Carter-Young, Inc.—a case centered around the Fair Credit Reporting Act (FCRA). The federal appellate vacated the ruling of a district court. It held that both legal disputes and factual disputes can form the basis of an FCRA claim. Our credit report error attorney provides a more comprehensive overview of the case, the decision, and its implications.
Case Review: Roberts v. Carter-Young, Inc.
Background and Facts
In November of 2019, Shelby Roberts entered into a lease agreement with a landlord to rent an apartment in North Carolina. After the initial lease term ended in September 2020, Ms. Roberts transitioned to a 60-day lease agreement. That later became a month-to-month tenancy. A dispute arose when the landlord allegedly attempted to lease Mr. Roberts’ apartment to another tenant without providing the required 30-day notice. Roberts refused to vacate. A dispute arose, and the landlord hired Carter-Young—a debt collection agency—to presume money that was allegedly owed. However, Ms. Roberts disputed the debt and that triggered FCRA requirements.
The Legal Issue
Why is this case so important? It has a core legal issue that needs to be resolved: The court was tasked with determining whether or not a furnisher has an obligation under the FCRA to conduct a reasonable investigation of disputed information that extends to disputes that involve legal questions, not just purely factual issues.
More specifically, the question in the case was whether Carter-Young (the debt collector) was required to investigate Ms. Roberts’ dispute—she alleged that the landlord fabricated charges—or whether it merely had the duty to confirm the existence of the debt as claimed by the original creditor.
Fourth Circuit Decision
Upon review, the Fourth Circuit vacated the district court’s dismissal of Roberts’ claim and remanded the case for further proceedings. The appellate court held that the FCRA requires furnishers—including debt collectors—to conduct a reasonable investigation of disputes concerning the completeness or accuracy of the information they have provided to credit reporting agencies—and that is true regardless of whether the disputes involve legal or factual questions. The court emphasized that the terms “completeness” and “accuracy” under the FCRA include information that is “objectively and readily verifiable.”
The Implications
The Fourth Circuit’s decision in Roberts v. Carter-Young, Inc. has big implications for the FCRA. By rejecting the distinction between so-called “legal” and “factual” disputes in the context of a furnisher’s duty to investigate under the FCRA, the court has broadened the scope of what constitutes a reasonable investigation under the law. It is a good decision for consumers, and it aligns with rulings from other circuits, including the Second Circuit and the Eleventh Circuit.
Contact Our Credit Report Error Lawyer for Immediate Help
At The Kim Law Firm, LLC, our credit report error attorney has the experience that you can rely on. If you have any specific questions or concerns about your rights or your options under the FCRA, professional guidance is available. Contact us today for a fully confidential, no-obligation consultation. We help consumers exercise their rights under the FCRA nationwide.
