Here's some weekend reading: "Allowing inaccurate information back onto a credit report after deleting it because it is inaccurate is negligent." Stevenson v. TRW Inc., 987 F.2d 288, 293 (5th Cir. 1993). Actual damages include humiliation or mental distress, even if the consumer has suffered no out-of-pocket losses. Fischl v. General Motors Acceptance Corp., 708 F.2d 143, 151 (5th Cir.1983). In Pinner, 805 F.2d at 1265, the consumer was awarded $ 25,000 for mental distress because of the humiliation and embarrassment resulting from three credit denials and from lengthy dealings with the credit bureau. The court did, however, order a remittitur from the original jury award of $100,000 mental distress damages. Another consumer received $10,000 because of humiliation and embarrassment suffered from three denials of credit and from the fact that the credit bureau took several months to correct the credit report's inaccuracies. Thompson v. San Antonio Retail Merchants Ass'n, 682 F.2d 509, 513-14 (5th Cir.1982). In Collins v. Retail Credit Co., 410 F.Supp. 924, 936 (E.D.Mich.1976), the court awarded a consumer $21,750 for embarrassment and humiliation. In Morris v. Credit Bureau of Cincinnati, Inc., 563 F.Supp. 962, 969 (S.D.Ohio 1983), the consumer was awarded $10,000 for anguish and embarrassment even though, after he was denied credit, he explained the inaccuracies on his credit report and subsequently obtained credit. In Bryant v. TRW, Inc., 487 F.Supp. 1234, 1242-43 (E.D.Mich.1980), the district court awarded a consumer $8,000 for anguish resulting from denials of a mortgage due to inaccurate credit reports. The Sixth Circuit affirmed. 689 F.2d 72 (6th Cir.1982). Finally, in Millstone v. O'Hanlon Reports, Inc., 528 F.2d 829, 834-35 (8th Cir.1976), the Eighth Circuit upheld an award of $2,500 for mental anguish after an insurer cancelled the consumer's policy because of an inaccurate credit report. The FDCPA does not require proof of actual damages as a precursor to the recovery of statutory damages./6 See Bartlett v. Heibl, 128 F.3d 497, 499 (7th Cir. 1997
