United States Third Circuit

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Seamans v. Temple University, 12-4298

Summary judgment in favor of defendant-university on plaintiff's claims for negligent and willful violations of the Fair Credit Reporting Act (FCRA) in connection with defendant's reporting of certain information to a consumer reporting agency (CRA) concerning plaintiff's student loan is vacated and remanded, where: 1) the district court erred in concluding that the Higher Education Act (HEA) effectively exempts the Loan from FCRA's "aging off" provision indefinitely; 2) furnishers of consumer credit data remain obligated to report fully and accurately under FCRA regarding the collection history and date of delinquency for even an HEA-qualifying education loan; 3) plaintiff has raised a genuine issue of material fact as to whether defendant negligently failed to comply with its obligations under FCRA; and 4) plaintiff has stated a claim that would allow him to recover damages and punitive damages.

Appellate Information

  • Decided 02/21/2014
  • Published 02/21/2014




  • United States Third Circuit


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