Arrizon v. Transunion, LLC

Plaintiff was a member of a decertified class that was dismissed from a federal lawsuit against the defendant in which the plaintiffs alleged violations of the Fair Credit Reporting Act. After being dismissed from the federal lawsuit, plaintiff filed a case in state court asserting similar violations of the FCRA. Defendant moved to dismiss the complaint as untimely and argued that the FCRA’s statute of limitations could not be tolled pursuant to Illinois’ bar against cross-jurisdictional tolling. Plaintiff argued that the complaint was timely under Illinois’ equitable tolling doctrine. The trial court granted the motion to dismiss and plaintiff appealed. The appellate court affirmed, finding that the trial court did not err in dismissing the complaint because plaintiff failed to establish that the equitable tolling doctrine applied to plaintiff’s case. (LAVIN and PUCINSKI, concurring)