Persistent Reporting Errors
Resolving an Account Does Not Always Resolve Its Reporting
In Huizar v. Horizon Bank, a state court eliminated the consumer's remaining debt, but the bank kept verifying that same balance every time a new dispute came in. That led to a $2.865 million jury verdict in June 2026, made up of $365,000 in actual damages and $2.5 million in punitive damages. Once a debt has been paid off or cleared by a court, that update needs to carry through to the credit report.
Note the split: $2.5 million in punitive damages against $365,000 in actual damages. Punitive exposure in FCRA cases generally turns on how the conduct is characterized, which puts real weight on being able to document what was reviewed at each dispute. Specific exposure depends on the facts and on counsel's judgment.
An August ruling in Martinez v. Green Planet Mortgage shows how a servicing error can survive even after a mortgage is paid off. Martinez paid off his mortgage in April 2020, and the servicer confirmed that payoff each time he disputed the account. But the CRA later moved older late payments into more recent dates, so the account looked delinquent again even though it had long since been paid in full. This is the kind of divergence that shows up when furnishing history is compared against ACDV and AUD data.
The issue here was the incorrect dates listed and the missed chances to fix them. The court ruled in Martinez's favor on the investigation violation, and the case is headed to trial to determine damages.
For furnishers, it's important to confirm an account is paid or resolved, while also making sure the balance, status, and payment history all tell the same story.
If disputes on the same account keep coming back, the earlier response probably left something open. A free FCRA baseline review looks at where.