Every FCRA accuracy case in Maryland eventually cites Dalton v. Capital Associated Industries, Inc., 257 F.3d 409 (4th Cir. 2001). It is the Fourth Circuit's defining statement of what "inaccurate" means — and it arose from an employment background check gone wrong.
The facts
A background screening company reported that William Dalton had a felony conviction. In fact, he had pleaded guilty to a misdemeanor — third-degree assault. On the strength of the erroneous report, his job prospect evaporated. The district court granted summary judgment to the screener; the Fourth Circuit reversed.
The holding
The court adopted a two-pronged inaccuracy standard that remains the law of this circuit:
"A report is inaccurate when it is 'patently incorrect' or when it is 'misleading in such a way and to such extent that it can be expected to [have an] adverse[]' effect."
That second prong matters enormously: technically true but misleading reporting violates the FCRA too. And on the facts, the court held a reasonable jury could find the report crossed the line: "[A] reasonable jury could read the report as plainly indicating that Dalton was found guilty of a felony, third degree assault."
The court also revived Dalton's claim under § 1681k, the provision imposing strict procedures on agencies that report public-record information for employment purposes.
Why Dalton still matters
Twenty-five years later, the same errors recur constantly: charges reported at the wrong severity, dismissed counts reported as convictions, expunged cases resurrected from stale databases, one person's record grafted onto another's file. Dalton's misleading-effect prong is also the foundation for later Fourth Circuit decisions like Saunders (omitting a dispute can mislead) and this year's Roberts v. Carter-Young (legal inaccuracies count too — see our separate post).
If a background report mischaracterized your record — even "slightly" — the mischaracterization itself may be the violation. Bring us the report; the comparison against the actual court file is often the whole case.