Huizar v. TransUnion LLC: Court Says Reinvestigation Reasonableness Belongs to the Jury

Huizar v. TransUnion LLC is a December 17, 2025 Northern District of Indiana decision holding that whether TransUnion’s reinvestigation of the plaintiff’s credit dispute was “reasonable” under the FCRA presents factual issues that must be decided by a jury, not resolved on summary judgment. The court therefore denied competing motions for summary judgment on the core Fair Credit Reporting Act claims and set the case for trial.​

Case overview

• The plaintiff, Fabian Huizar, alleged that TransUnion repeatedly reported an inaccurate charge‑off on his credit reports after his underlying car loan dispute had already been arbitrated and resolved in his favor.​

• He brought claims under the Fair Credit Reporting Act (FCRA), including failure to follow reasonable procedures to assure maximum possible accuracy under 15 U.S.C. § 1681e(b) and failure to conduct a reasonable reinvestigation of his disputes under § 1681i.​

The court’s ruling on summary judgment

• Both Huizar and TransUnion moved for summary judgment, but the court denied both motions, explaining that the reasonableness of TransUnion’s reporting and its reinvestigation efforts raised genuine disputes of material fact.​

• The court emphasized that, given the competing evidence, a reasonable jury could find either that TransUnion acted reasonably or that it unreasonably continued to report inaccurate information despite Huizar’s disputes and the prior arbitration award.​

Why reinvestigation goes to the jury

• The decision underscores that whether a consumer reporting agency’s reinvestigation is “reasonable” under the FCRA is typically a fact‑intensive question suited for a jury, particularly where the record shows multiple disputes, third‑party determinations (like arbitration), and evolving furnisher responses.​

• The court noted that TransUnion’s reliance on automated or furnisher‑driven verification procedures, in the face of contrary information from the arbitration and from Huizar, created a classic jury issue on whether the investigation satisfied the FCRA’s reasonableness standard.​

Practical implications

• For plaintiffs, the case illustrates a pathway to trial where they can show: (1) a clear prior determination that an account is erroneous, (2) repeated disputes, and (3) continued reporting after reinvestigation that arguably ignores those facts.​

• For CRAs and furnishers, the ruling is a warning that simply echoing a furnisher’s verification or relying on standard automated processes may not warrant judgment as a matter of law when there is evidence that should prompt a more robust reinvestigation.​