Russell v. Chase Bank USA, NA (In Re Russell)
Nigel Anthony Russell initiated an adversary proceeding against Chase Bank USA, N.A., alleging violations of a bankruptcy discharge injunction and the Fair Credit Reporting Act, along with a claim for defamation. Russell contended that Chase intentionally failed to update his credit reports to reflect a discharged debt, thereby attempting to coerce payment. Chase filed a motion to dismiss all claims. The court granted the motion to dismiss the defamation claim due to lack of subject matter jurisdiction, finding it not "related to" the bankruptcy estate. However, the court denied the motion to dismiss the discharge injunction violation claim, ruling that a deliberate refusal to correct credit information could be considered an act to collect a discharged debt, and further noted that punitive damages might be warranted if willful misconduct is proven.