9th Cir.;
14-17186

The court of appeals reversed a district court judgment of dismissal and remanded. The court held that a prospective employer violates the Fair Credit Report Act’s (FCRA) disclosure requirements when it procures a job applicant’s consumer report after including a liability waiver in the same document as the statutorily mandated disclosure. The court held further that an employer’s violation is “willful” when it includes terms in addition to the disclosure, such as the liability waiver at issue here, before procuring a consumer report or causing one to be procured.