Legal Environment of Business
Johnson v. MBNA Bank, N.A.
357 F.3d 426
United States Court of Appeals,
Linda JOHNSON, Plaintiff-Appellee,
MBNA AMERICA BANK, NA, Defendant-Appellant, and Experian Information
Solutions, Incorporated; Equifax Credit Information Services, Incorporated;
Trans Union LLC, Defendants.
Argued: Dec. 4, 2003.
Decided: Feb. 11, 2004.
Affirmed by published opinion. Chief Judge wrote the opinion, in which Judge and Judge BENNETT joined.
, Chief Judge:
MBNA America Bank, N.A. (MBNA) appeals a judgment entered against it following a jury verdict in favor of Linda Johnson
in her action alleging that MBNA violated a provision of the Fair Credit Reporting Act (FCRA),
(West 1998) (amended
Dec. 4, 2003), by failing to conduct a reasonable investigation of Johnson's dispute concerning an MBNA account appearing
on her credit report. Finding no reversible error, we affirm.
The account at issue, an MBNA MasterCard account, was opened in November 1987. The parties disagree regarding who
applied for this account and therefore who was legally obligated to pay amounts owed on it. It is undisputed that one of the
applicants was Edward N. Slater, whom Johnson married in March 1991. MBNA contends that Johnson was a co-applicant
with Slater, and thus a co-obligor on the account. Johnson claims, however, that she was merely an authorized user and not
In December 2000, Slater filed for bankruptcy, and MBNA promptly removed his name from the account. That same month,
MBNA contacted Johnson and informed her that she was responsible for the approximately $17,000 balance on the account.