Department of Agriculture Rural Development Rural Housing Service v. Kirtz
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Department of Agriculture Rural Development Rural Housing Service v. Kirtz and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Department of Agriculture Rural Development Rural Housing Service v. Kirtz.
The Supreme Court addressed whether the Fair Credit Reporting Act (FCRA) allows consumers to sue federal agencies for damages. The Court found that the FCRA clearly waives sovereign immunity for federal agencies, permitting such suits. The decision affirms the Third Circuit's ruling that the FCRA's definition of 'person' includes government agencies.
Holding
The single most important “bottom line” of what the Court decided in Department of Agriculture Rural Development Rural Housing Service v. Kirtz.
The Court held that a consumer may sue a federal agency for defying the FCRA's terms.
Constitutional Concepts
These are the Constitution-related themes that appear in Department of Agriculture Rural Development Rural Housing Service v. Kirtz. Click a concept to see other cases that involve the same idea.
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Why State Sovereign Immunity is relevant to Department of Agriculture Rural Development Rural Housing Service v. Kirtz
The case primarily deals with whether the FCRA waives sovereign immunity for federal agencies, allowing them to be sued for damages.
Syllabus excerpt (verbatim)Held: A consumer may sue a federal agency for defying the FCRA's terms.
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Why Commerce Clause is relevant to Department of Agriculture Rural Development Rural Housing Service v. Kirtz
The FCRA was enacted pursuant to Congress's power under the Commerce Clause, which is relevant to the discussion of state sovereign immunity.
Syllabus excerpt (verbatim)The government finds that result unthinkable because Congress enacted the FCRA pursuant to the Constitution's Commerce Clause.
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Why Judicial Review is relevant to Department of Agriculture Rural Development Rural Housing Service v. Kirtz
The Court is exercising its power to interpret the statute and determine the applicability of sovereign immunity.
Syllabus excerpt (verbatim)What matters is whether Congress has authorized a waiver of sovereign immunity that is 'clearly discernible' from the sum total of its work.
Key Quotes
Short excerpts from the syllabus in Department of Agriculture Rural Development Rural Housing Service v. Kirtz that support the summary and concepts above.
A consumer may sue a federal agency for defying the FCRA's terms.
The FCRA clearly waives sovereign immunity in cases like this one.
Sections 1681n and 1681o create a cause of action for money damages to consumers injured by '[a]ny person' who willfully or negligently fails to comply with the statute's directive.
