In 1989, John M. Stevenson began receiving phone calls from bill collectors regarding overdue accounts that were not his. After Stevenson obtained a copy of his credit report from TRW, Inc., a credit-reporting agency, he discovered numerous errors in the report. The report included information on accounts that belonged to another John Stevenson; it also included accounts belonging to his estranged son, John Stevenson, Jr., who had fraudulently obtained some of the disputed accounts by using the senior Stevenson’s Social Security number. In all, Stevenson disputed sixteen accounts, seven inquiries, and much of the identifying information.

TRW investigated the complaint. On February 9, 1990, it told Stevenson that all disputed accounts containing negative credit information had been removed. Inaccurate information, however, either continued to appear on Stevenson’s reports or was reentered after TRW had deleted it. Stevenson then filed suit, alleging both common law libel and violations of the Fair Credit Reporting Act. Did TRW violate the Fair Credit Reporting Act in its handling of Stevenson’s dispute? [Stevenson v. TRW, Inc., 987 F.2d 288 (5th Cir. 1993).]