Complaint Against Property Receivables Corp. with Jury Demand Filed by Zahkia I. Morgan. (Attachments: # 1 Civil Cover Sheet, # 2 Proposed Summons)(Brooks, Maxwell)

Document #1 Filed 03/30/2026 · 7 pages · District Court, M.D. Florida · View original PDF

NATURE OF THE ACTION

Plaintiff brings this action seeking redress for violations of the Fair Credit Reporting

Act (“FCRA”) pursuant to 15 U.S.C. §1681 et seq.

JURISDICTION AND VENUE

The Court has federal question jurisdiction pursuant to 28 U.S.C. §1331 as the

FCRA is a federal statute.

Venue in this district is proper under 28 U.S.C. § 1391(b)(2) as a substantial part

of the events and omissions giving rise to Plaintiff’s claims occurred in this judicial district.

PARTIES

4Plaintiff is a natural person over 18-years-of-age, who at all times relevant resided in Land O’ Lakes, Florida.

5Defendant is a Delaware limited liability corporation with its principal place of business located in Chicago, Illinois. TransUnion is regularly engaged in the business of assembling, evaluating, and disbursing information concerning consumers for the purpose of furnishing consumer reports and credit files to third parties bearing on a consumer’s credit worthiness, credit standing, and credit capacity on a nationwide basis, including in the State of Florida.

FACTUAL ALLEGATIONS

6In or around July 29, 2025, Plaintiff moved out of her apartment owned by Tricon Residential (“Tricon”).

7After Plaintiff vacated her apartment, she was credited in the amount of $3,374.10.

8On September 24, 2025, Plaintiff received a letter from Defendant stating that she owed $3,783.59 (“subject debt”) to Tricon Residential and they were attempting to collect this debt.

9On October 6, 2025, Plaintiff sent a dispute email containing her move out statement showing that she was credited $3,374.10 to Tricon’s management and Tricon.

10Upon information and belief, Defendant still reported the subject debt on Plaintiff’s credit reports with Ticon and TransUnion.

11Plaintiff disputed this alleged subject debt with Defendant.

12Despite receiving notice of the move out statement showing Plaintiff was credited, and did not owe Tricon Residential, the subject debt still appeared on her TransUnion credit report.

13On November 30, 2025, Plaintiff’s TransUnion credit report stated a balanced owed of $3,819.

14Plaintiff has since disputed this charge with TransUnion.

15Plaintiff further suffered emotional distress, and extreme anxiety as a result of Defendant’s erroneous credit reporting

16Frustrated with Defendant’s unfair and deceptive conduct, Plaintiff retained counsel to compel the Defendants to cease its unlawful collection practices and to vindicate her rights.

IMPACT OF INACCURATE REPORTING ON PLAINTIFF’S CREDIT FILE

17The erroneous reporting of the inaccurate information paints a false and damaging image of Plaintiff. Specifically, the inaccurate reporting of the Plaintiff’s information has had a significant adverse impact on Plaintiff’s credit rating and creditworthiness because it misleads creditors into believing that Plaintiff cannot honor her financial obligations and is thus a high-risk consumer.

18In an effort to remedy the continued inaccurate and materially misleading reporting of the fraudulent information and to validate the accuracy of Defendant’s inaccurate credit reporting.

19The entire experience has imposed upon Plaintiff significant distrust, frustration, distress, and has rendered Plaintiff helpless as to her ability to regain a firm foothold on her creditworthiness, credit standing, and credit capacity.

20As a result of the conduct, actions, and inactions of the Defendant, Plaintiff has suffered various types of damages as set forth herein, including specifically, increased insurance premiums, increased interest rates, expenses and time incurred curing and remediating fraudulent account activity, time and expenses reasonably incurred to prevent future fraudulent activity, credit monitoring, constant vigilance in detecting fraudulent account activity, out-of-pocket expenses, loss of the use of funds, local or long distance telephone calls, postage, time and money expended meeting with her attorneys, tracking the status of her disputes, monitoring her credit files, mental and emotional pain and suffering, and other frustration and aggravation associated with disputing the fraudulent information that does not belong to Plaintiff.

21Due to the conduct of Defendants, Plaintiff was forced to retain counsel to correct the inaccuracies in her Transunion credit files.

COUNT I – VIOLATIONS OF THE FAIR CREDIT REPORTING ACT

22Plaintiff repeats and realleges all preceding paragraphs as though fully set forth herein

23TransUnion is a “consumer reporting agency” as defined by 15 U.S.C. §1681a(f).

24TransUnion is a “consumer reporting agency that compiles and maintains files on consumers on a nationwide basis” as defined by 15 U.S.C. §1681a(p).

25At all times relevant, the above-mentioned credit reports were “consumer reports” as that term is defined by §1681a(d).

26At all times relevant, Plaintiff was a “consumer” as the term is defined by 15 U.S.C. §1681a(c).

27The FCRA mandates that “[w]henever a consumer reporting agency prepares a consumer report it shall follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates.” 15 U.S.C. § 1681e(b).

28The FCRA requires the credit reporting industry to implement procedures and systems to promote accurate credit reporting.

29If a consumer notifies a credit reporting agency of a dispute concerning the accuracy of any item of credit information, the FCRA requires the credit reporting agency to conduct a reasonable investigation to determine whether the disputed information is inaccurate and record the current status of the disputed information or delete the disputed information within 30 days of receiving the dispute. 15 U.S.C. §1681i(a)(1)(A).

30Plaintiff provided Trans Union with all relevant information and documentation in his dispute to support his contention that the disputed account was reporting inaccurately.

31A cursory review of the evidence submitted by Plaintiff would have confirmed that the disputed account was reporting inaccurately.

32TransUnion failed to conduct a meaningful investigation into Plaintiff’s dispute. Instead, it continued to blindly report the false information provided to it by Plaintiff.

33TransUnion violated 15 U.S.C. §1681e(b) by failing to establish or to follow reasonable procedures to assure maximum possible accuracy in preparation of the consumer reports it furnished and refurnished concerning Plaintiff.

34TransUnion repeatedly distributed patently false and materially misleading consumer reports concerning Plaintiff to third parties.

35TransUnion failed to follow reasonable procedures to assure maximum possible accuracy by repeatedly ignoring the evidence provided by Plaintiff and blindly accepting erroneous information furnished to it by TRICON as accurate.

36Had TransUnion followed reasonable procedures to assure maximum possible accuracy, it would have reviewed the dispute and evidence submitted by Plaintiff and promptly discovered that the disputed account was reporting inaccurately. Instead, TransUnion repeatedly accepted erroneous information as true and continued the reporting of the erroneous information pertaining to the disputed account.

37TransUnion should have implemented procedures and safeguards to prevent repeated reporting inaccurate information regarding the account.

38TransUnion violated 15 U.S.C. §1681i(a)(1) by failing to (1) conduct a reasonable investigation into Plaintiff’s dispute and (2) modify the account to report accurately on Plaintiff’s credit file.

39Had TransUnion conducted a reasonable investigation into Plaintiff’s valid dispute, it would have promptly determined that the disputed account was reporting incorrectly.

40TransUnion took no meaningful action to determine whether the disputed account was reporting incorrectly and blindly reported the same with no regard to its accuracy.

41At very minimum, TransUnion should have requested that TRICON provide proof that its

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