Williams v. Trans Union LLC

── Williams v. Trans Union LLC ── Court: Court of Appeals for the Second Circuit Date: April 16, 2026 Category: General 25-37 Williams v. Trans Union LLC UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL. At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 16th day of April, two thousand twenty-six. PRESENT: ROBERT D. SACK, RICHARD J. SULLIVAN, EUNICE C. LEE, Circuit Judges. _____________________________________ STEPHEN JOHN WILLIAMS, Plaintiff-Appellant, v. No. 25-37 TRANS UNION LLC, a Delaware general Liability Company,  Defendant-Appellee. _____________________________________ For Plaintiff-Appellant: STEPHEN J. WILLIAMS, pro se, Storrs, CT. For Defendant-Appellee: CAMILLE R. NICODEMUS, Quilling, Selander, Lownds, Winslett & Moser, P.C. Indianapolis, IN. Appeal from an order of the United States District Court for the District of Connecticut (Jeffrey A. Meyer, Judge). UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the December 2, 2024 judgment of the district court is AFFIRMED. Stephen John Williams, an attorney proceeding pro se, appeals from the district court’s dismissal of his claims under the Fair Credit Reporting Act (the “FCRA”), 15 U.S.C. § 1681c(a), against Trans Union LLC. On appeal, Williams contends that the district court (i) erred in concluding that his consolidation of previously defaulted student loans constituted a “new” loan under the FCRA; (ii) deprived him of ”[c]onstitutional due process” by rejecting his FCRA claims without first ruling on his procedural objections to Trans Union’s motion to dismiss, Williams Br. at 3; and (iii) incorrectly failed to “provid[e] [an] opportunity for amendment,” id. at 18. We assume the parties’ familiarity with the underlying 2 facts, procedural history, and issues on appeal, to which we refer only as necessary to resolve this appeal. We “review de novo a district court’s grant of a motion to dismiss, accepting as true all factual allegations in the complaint and drawing all reasonable inferences in favor of the plaintiff[].” Muto v. CBS Corp., 668 F.3d 53, 56 (2d Cir. 2012). Meanwhile, we review a district court’s decision not to spontaneously grant leave to amend for abuse of discretion. Williams v. Citigroup Inc., 659 F.3d 208, 212 (2d Cir. 2011). Finally, while we “ordinarily . . . afford[] a special solicitude to pro se litigants,” “a lawyer representing himself” – like Williams – generally will “receive[] no such solicitude at all.” Tracy v. Freshwater, 623 F.3d 90, 101–02 (2d Cir. 2010). Williams first argues that the district court improperly construed section 1681c(a) of the FCRA, which requires credit agencies preparing “consumer reports” to “exclude[]” certain loans that “antedate[] the report by more than seven years.” 15 U.S.C. § 1681c(a). Williams contends that this seven-year rule should have blocked Trans Union from reporting his 2023 loa