Parsonage v. Wal-Mart Assocs., Inc., 118 Cal. App. 5^th 399 (2026)

Before beginning employment with Wal-Mart, Tina Parsonage executed a “Background Report Disclosure” form that authorized Wal-Mart to conduct a background check on her.  Three years later, Parsonage sued Wal-Mart for violating the California Investigative Consumer Reporting Agencies Act (ICRAA, Cal. Civ. Code § 1786, et seq.) by failing to identify the name, address, and telephone number of the particular agency that conducted the investigation and by failing to provide a checkbox to request a copy of the report and also by failing to supply the required certification of compliance to the furnishing agency before procuring the report.  Pursuant to the statute, Parsonage sought recovery of damages in the amount of $10,000 for each violation of the ICRAA.  Wal-Mart successfully moved for summary judgment on the ground that Parsonage had no standing to sue because she suffered no injury or harm from the “technical violations” of the statute and had received the job for which she had applied.  The Court of Appeal reversed, holding that plaintiffs need not show any injury beyond a violation of their rights in order to have standing under the ICRAA.  In reaching that conclusion, the Court declined to follow cases interpreting the federal Fair Credit Reporting Act, which does require a showing of injury to establish standing.