Background
Brittney Moseley brought a civil action against Latino Community Credit Union alleging violations of the Fair Credit Reporting Act, specifically 15 U.S.C. § 1681b. The district court for the Western District of North Carolina granted summary judgment to the credit union.
Moseley, proceeding pro se on appeal, challenged that ruling in the Fourth Circuit. The appellate court reviewed only the issues preserved in her informal brief, as required by Fourth Circuit Rule 34(b).
The Court’s Holding
In an unpublished per curiam opinion, the Fourth Circuit affirmed the district court’s order. After reviewing the record and the issues raised in Moseley’s informal brief, the court found no reversible error.
The court did not provide a detailed analysis of the asserted FCRA violations or the district court’s reasoning. It affirmed the December 22, 2025 order and dispensed with oral argument because the written materials adequately presented the facts and legal contentions and argument would not aid the decisional process.
Key Takeaways
- The Fourth Circuit upheld summary judgment for Latino Community Credit Union on Moseley’s FCRA claim.
- In a pro se appeal, the court limits its review to issues preserved in the appellant’s informal brief.
- The unpublished per curiam decision found no reversible error and is not binding precedent in the Fourth Circuit.
Why It Matters
The decision reinforces the importance of clearly identifying each appellate issue in an informal brief. Even for pro se litigants, issues not preserved in that filing generally fall outside the Fourth Circuit’s review.
Because the opinion summarily affirmed without substantive discussion of 15 U.S.C. § 1681b and is unpublished, it offers limited guidance on the merits of future FCRA disputes.