Johnson v. MBNA America Bank, NA 357 F.3d 426 (4th Cir.

2004)
The MBNA agents also testified that, in investigating consumer disputes generally, they do not look
beyond the information contained in the CIS and never consult underlying documents such as account
applications. Based on this evidence, a jury could reasonably conclude that MBNA acted unreasonably
in failing to verify the accuracy of the information contained in the CIS.

Robbins v. CitiMortgage, Inc. Case No. 16-CV-04732-LHK (N.D. Cal. Dec. 20, 2017)
Holding a jury could find that a furnisher's failure to look beyond internal information constituted an
unreasonable investigation.

Carlisle v. Nat'l Commercial Servs., Inc. CIVIL ACTION NO. 1:14-CV-515-TWT-LTW (N.D. Ga. Jun. 12,
2015)
Holding that creditor's investigation into consumer's dispute that she did not apply for the account and
was not legally obligated to pay was not reasonable where creditor merely confirmed that the name and
address sent by the consumer reporting agencies were the same as the name and address listed on its
computer system and did not do anything to verify the information in its computer system.

Walton v. Chase Home Fin. LLC 1:11-cv-00417-JMS-MJD (S.D. Ind. Dec. 18, 2012)
Denying summary judgment in favor of bank where, in resolving dispute regarding whether plaintiff
was a co-obligor of loan, bank did not consult underlying loan documents and, thus, "a jury could
reasonably conclude that [the bank] acted unreasonably in failing to verify the accuracy of the
information...."

Davidson v. Capital One, N.A. CASE NO. 14-20478-CIV-ALTONAGA/O'Sullivan (S.D. Fla. Nov.
25, 2014)
Noting Congress "creat[ed] a system intended to give consumers a means to dispute — and, ultimately,
correct — inaccurate information on their credit reports" (alteration added; citations omitted)

Apodaca v. Discover Financial Services 417 F. Supp. 2d 1220 (D.N.M. 2006)

Henson, 29 F.3d at 286-87. In such situations, "[i]t would make little sense to conclude that, in creating
a system intended to give consumers a means to dispute — and, ultimately, correct — inaccurate
information on their credit reports, Congress used the term `investigation' to include [only]
superficial . . . inquiries by creditors" that "do not look beyond the [automated] information" in their
own computer systems and " never consult underlying documents such as account applications " and
the like. Johnson, 357 F.3d at 430-31.

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