Missouri Court of Appeals, Western District / Mar 17, 2020
Rebecca Courtright, et al vs. O'Reilly Automotive
Prospective employees sued O'Reilly Automotive, alleging violations of the Fair Credit Reporting Act (FCRA) for revoking conditional job offers based on consumer reports without prior disclosure. The circuit court granted O'Reilly's motion to dismiss for lack of standing, which was converted to a summary judgment motion on appeal. The appellate court reversed in part, finding that one plaintiff, Mr. Bradley, had standing for his adverse-action claim because he suffered a concrete injury from inaccurate information coupled with the employer's procedural violation. However, the court affirmed the summary judgment against the other plaintiffs, Ms. Courtright and Mr. Saye, on their adverse-action claims, and against Mr. Saye and Mr. Estrada on their disclosure and authorization claims, concluding they failed to establish a concrete injury or dispute material facts.