The California Fourth Appellate District, Division One, recently held that an employee or job applicant does not need to prove actual harm beyond establishing a statutory violation to have standing under the California Investigative Consumer Reporting Agencies Act (ICRAA) (Parsonage v. Wal-Mart (2026). The court concluded that the California Legislature intended the ICRAA to provide stronger consumer protections than its federal counterpart — the Fair Crediting Reporting Act (FCRA). Employers can now face liability regardless of whether the employee or job applicant was harmed by not getting the job or promotion. Now, potential plaintiffs merely must show noncompliance with the disclosure requirements of ICRAA.

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