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Samuel Edeh v. Midland Credit Management

Samuel N. EDEH, Appellant, v. MIDLAND CREDIT MANAGEMENT, INC., Appellee

Edeh v. Midland Credit Mgmt., 413 F. App'x 925 (8th Cir. 2011)
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Court
Court of Appeals for the Eighth Circuit · U.S. Courts of Appeals
Decided
March 17, 2011
Docket
No. 10-3441
Judges
Bye, Arnold, Shepherd
Citations
413 F. App'x 925
Status
Unpublished

Opinion — Per Curiam

PER CURIAM.

Samuel N. Edeh appeals the district court’s 1

adverse grant of summary judgment on his claim against Midland Credit Management, Inc. (Midland) under the Fair Credit Reporting Act.

See 15 U.S.C. § 1681s-2(b) (duties of furnishers of information to credit reporting agency (CRA) upon notice from CRA of dispute over completeness or accuracy of information).

2

Having carefully reviewed the record, we find that there were no trialworthy issues on whether Midland’s investigation was reasonable.

See Conseco Life Ins. Co. v. Williams, 620 F.3d 902, 907 (8th Cir.2010) (de novo standard of review; grant of summary judgment may be affirmed on any basis supported by record);

see also Westra v. Credit Control of Pinellas, 409 F.3d 825, 827 (7th Cir.2005) (reasonableness of investigation is factual question normally reserved for trial, but summary judgment is proper when reasonableness is beyond question). The notices the CRAs provided to Midland provided little, if any, detail as to the basis for Edeh’s dispute, see Westra, 409 F.3d at 827 (investigation was reasonable given scant information concerning nature of creditor’s dispute); and the reasons provided in these notices were also inconsistent. Further, contrary to Edeh’s assertions on appeal as to what constitutes a reasonable investigation whenever a debt is disputed, a furnisher of information need investigate only what is contained in the CRA’s dispute notice as to the nature of the dispute.

See Anderson v. EMC Mortg. Corp., 631 F.3d 905, 908-09 (8th Cir.2011);

see also Chiang v. Verizon New England, Inc., 595 F.3d 26, 38 (1st Cir.2010) (more limited investigation may be appropriate when CRAs provide furnisher with vague or cursory information about consumer’s dispute). It was thus enough for Midland to check the information it received from the seller of the debt to verify that Edeh was the one who owed it *927 and how much he owed. Accordingly, we affirm.

1

. The Honorable Patrick J. Schütz, United States District Judge for the District of Minnesota.

2

. The district court entered final judgment after the parties stipulated to a dismissal with prejudice of Edeh’s other claims.

How later courts describe this case

Explanatory parentheticals written by citing courts — 1 in all; the most informative distinct ones are shown.

Cited by 15 cases

View all citing references →
2013: 32014: 22016: 12020: 22021: 12023: 22024: 22026: 220132026peak 2013 · 3

Relies on it most ⓘ

  1. McIvor v. Credit Control Services, Inc.987 F. Supp. 2d 968 (D. Minnesota 2013)
  2. Sarah McIvor v. Credit Control Services, Inc.773 F.3d 909 (8th Cir. 2014)
  3. Humes v. LVNV Funding, L.L.C. (In re Humes)496 B.R. 557 (Bankr. E.D. Ark. 2013)
  4. Pleasant v. Noble Finance Corp.54 F. Supp. 3d 1071 (W.D. Mo. 2014)
  5. Aubert v. Russell Collection Agency, Inc.215 F. Supp. 3d 583 (E.D. Mich. 2016)
  6. Smith v. Encore Capital Group Inc.966 F. Supp. 2d 817 (E.D. Wis. 2013)

Most recent

  1. Melissa Taylor v. Mariner Finance, LLC; JP Morgan Chase Bank, N.A.; Discover Financial Services, LLC; Equifax Information Services, LLC; Experian Information Solutions, Inc.; and Trans Union, LLCNo. 0:25-cv-00060 (D. Minnesota Aug. 10, 2026)
  2. Lea Johnson v. Freedom Mortgage Corp.No. 24-2787 (8th Cir. Feb. 2, 2026)
  3. Ward v. National Credit Systems, Inc.No. 1:21-cv-02597 (D. Colo. June 5, 2024)
  4. Thomas v. LexisNexis Risk Solutions IncNo. 4:23-cv-00312 (E.D. Ark. May 29, 2024)
  5. Radford v. Loancare, LLCNo. 4:21-cv-01368 (E.D. Mo. May 2, 2023)
  6. Weber v. Experian Information Solutions, Inc.No. 1:21-cv-04807 (E.D.N.Y. Mar. 23, 2023)

Citing references are not a citator: they show that a later opinion cites this case, not whether it followed, distinguished, or overruled it. Check negative history before relying on this case.

Authorities cited 4

DepthCaseCited by
Dirk Westra v. Credit Control of Pinellas, 409 F.3d 825 (7th Cir. 2005) 120
Chiang v. Verizon New England, Inc., 595 F.3d 26 (1st Cir. 2010) 249
Conseco Life Ins. v. Williams, 620 F.3d 902 (8th Cir. 2010) 92
Anderson v. EMC Mortg. Corp., 631 F.3d 905 (8th Cir. 2011) 31

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