Paniani Taafua v. Quantum Global Technologies, LLC
Opinion
Trial Court Opinion
facts, must conform as much as possible to the requirements of Fed. R. Civ. P. 56(e), and must settlement.2 I. BACKGROUND A. The FCRA and Mr. Taafua’s Claims “The FCRA seeks to ensure ‘fair and accurate credit reporting.’” Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1545 (2016) (quoting 15 U.S.C. § 1681(a)(1)). As relevant here, the FCRA imposes certain requirements on those who seek to obtain consumer reports3 for employment purposes. 15 U.S.C. § 1681b(a)(3)(B). At issue in this action is the FCRA’s so-called “stand- alone disclosure” requirement, which essentially requires that a person seeking to procure a consumer report for employment purposes must first (1) provide the subject consumer with a “clear and conspicuous disclosure . . . in a document that consists solely of the disclosure” that such a report may be obtained and (2) obtain the consumer’s written authorization:
Except as provided in subparagraph (B), a person may not procure a consumer report, or cause a consumer report to be procured, for employment purposes with respect to any consumer, unless—
(i) a clear…