Ga. Puts Up Another Hurdle For Class Certification

Law360, New York (March 27, 2013, 12:31 PM EDT) -- In Farmer v. The Phillips Agency, 285 F.R.D. 685 (N.D. Ga. 2012), the U.S. District Court for the Northern District of Georgia denied a plaintiff's motion to certify a class action under the Fair Credit Reporting Act (FCRA) consisting of all individuals who had been the subject of an adverse criminal background report, whether accurate or inaccurate, generated by the defendant, The Phillips Agency.

In doing so, the Northern District of Georgia became the first court to explicitly state that a plaintiff bringing claims under Section...
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