Judge Schroeder’s September 30, 2025 portrait of the property report as a CRA in Joyce v. First American Mortgage Solutions, LLC (No. 1:23-cv-1069) denied the defendant’s motion for judgment on the pleadings, allowing a Fair Credit Reporting Act (“FCRA”) claim to proceed where a “Property Report” combined another consumer’s judgments with the plaintiff’s file and was then used by a lender to deny him a loan.
In this sequel to Keller v. Experian I, 2024 WL 1349607 (M.D.N.C. Mar. 30, 2024), Judge Thomas Schroeder once again dismissed Eric Keller’s Fair Credit Reporting Act (FCRA) suit against Experian—this time for lack of Article III standing rather than for failure to state a claim.
When a repossession turns into a shouting match—or worse, when the debtor is still inside the car—any lawyer who’s ever seen the phrase “without breach of the peace” in N.C. Gen. Stat. § 25-9-609 should immediately start thinking “state-court claim and delivery,” not “self-help.”
In Pelc v. Pham (No. COA25-27, filed Oct. 15, 2025), the North Carolina Court of Appeals (Tyson, J.) vacated a Mecklenburg County contempt order imprisoning a former spouse for failure to pay a contractual debt arising from a Form I-864 “Affidavit of Support” and related loan. The appellate court held that the trial court lacked jurisdiction to use contempt powers to enforce a money judgment grounded in breach of contract.
In this unpublished but instructive decision, Judge Wood (joined by Judges Stroud and Carpenter) affirmed the dismissal of an attempted “flip” real-estate buyer’s sprawling complaint after the collapse of a $2.7 million contract to buy the Seawatch at Sunset Harbor subdivision in Brunswick County.
In In re Ryan Lashon Ford, Judge Edwards issued two companion opinions chronicling the court’s escalating efforts to bring order to what she aptly described as an “atypical” pro se Chapter 7 case that had metastasized into a performative exercise in pseudo-law.
Trenita Rogers bought her Winterville home in 2010, subject to the Irish Creek HOA. In 2021, after allegedly failing to pay $1,391.23 in assessments, the HOA filed liens and moved forward with foreclosure. Notice was attempted by certified mail during the USPS’s Covid-19 “contactless” protocol—where carriers often signed “C19” themselves instead of obtaining the addressee’s signature—and by sheriff posting without a proper court order.
