The First Appellate District affirmed a judgment. The court held that the federal Fair Credit Reporting Act, 15 U.S.C. §1681 et seq., preempts, without exception, any private right of action under California’s Consumer Credit Reporting Agencies Act, Civ. Code §1785.1 et seq.

Rebecca Liceaga’s car and purse were stolen, and her identity was used to obtain a Sprint cell phone account. Although Liceaga had never done any business with Sprint, she was dunned by Debt Recovery Solutions, LLC, a debt collection agency, after the identity thief failed to pay the Sprint account.