Watson v. Caruso

Adrien Watson (plaintiff) was convicted of second-degree sexual assault in 1998 but later successfully petitioned the state of Connecticut to erase the conviction after the Connecticut legislature decriminalized the relevant conduct. In 2018, Watson began working for the St. Vincent DePaul Mission of Bristol (SVDP), which was part of the Catholic Diocese of Hartford. The diocese engaged Mind Your Business (MYB) (defendant) to perform a background check on Watson. MYB’s search results included Watson’s sexual-assault conviction and labeled Watson as a sex offender but did not mention Watson’s successful petition to erase the conviction. MYB prepared a report based on the search results and provided the information to SVDP without notifying Watson that Watson’s criminal-record information was being reported. Based on MYB’s report, SVDP revoked Watson’s employment offer. Watson sued MYB and MYB’s owner, Karen Caruso (defendant), asserting that MYB had violated the Fair Credit Reporting Act (FCRA) by providing an inaccurate report that included the 1998 conviction. MYB and Caruso moved for summary judgment, asserting that the report’s information about the conviction was factually accurate as a matter of law and that MYB had obtained the conviction information from RapidCourt, which was a reliable third-party vendor.