Robinson v. Equifax Information Services, LLC, 560 F.3d 235 (4th Cir. 2009), is one of the Fourth Circuit's clearest statements that years of failed disputes have a price — and that juries are allowed to set it.
The facts
After identity thieves used Angela Robinson's personal information, Equifax's systems repeatedly linked and blended fraud-created data with her true file. From 2003 through 2006 she disputed again and again; the contamination kept resurfacing, and the polluted file blocked her from favorable mortgage credit when she needed it. The jury awarded $200,000 in actual damages, and the Fourth Circuit affirmed, emphasizing the systemic nature of the failure:
"Robinson did not suffer from isolated or accidental reporting errors. Rather, as a victim of identity theft, she suffered the systematic manipulation of her personal information."
Her damages evidence checked every box the circuit's Sloane decision requires: concrete lost opportunities (mortgage financing), quantified lost time (roughly 300 hours), and corroborated emotional distress.
The attorney-fee footnote that teaches a lesson
One nuance worth knowing: the district court had awarded over $268,000 in attorney's fees, and the Fourth Circuit vacated that award — not because fees were unavailable, but because the fee petition's proof of prevailing market rates was inadequate, requiring a remand. The FCRA's fee-shifting provision is powerful, but it must be exercised with rigor. (It is also a reminder of how the economics work: the statute is designed so that the defendant, not the consumer, ultimately bears the cost of vindicating accuracy.)
The takeaway
If a bureau keeps "fixing" your file only for the same fraud to reappear — re-pollution, re-linking, re-aging — you are not stuck writing dispute letters forever. Robinson shows that persistent systemic failure is compensable at six figures in this circuit. Bring the whole paper trail: every confirmation number, every "results of reinvestigation" letter, every denial. Patterns win these cases.