October Term 2006 · Docket 06-84

Does willful violation require actual knowledge or include reckless disregard?

Safeco argues willfulness requires actual knowledge. Burr argues it includes reckless disregard of legal duties.

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Safeco Ins. Co. of America v. Burr
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Verified source milestones

  1. — An official oral-argument transcript was verified.

The arguments, in order

This case may have been argued more than once. Each entry below uses that session's official transcript. Later arguments do not erase earlier ones.

  1. Argument 1 ·

    What happened at the argument

    Ms. Mahoney argued the Ninth Circuit's interpretation of willfulness was flawed. She requested a remand to explore communications with counsel.

    Mr. Shorr argued Congress intended to require knowing violations when it used specific language. He claimed the statute here lacks that explicit requirement.

    Ms. Millett argued the Court of Appeals correctly included a reckless disregard component. She asserted this fits the civil context of the law.

    Read the official transcript for this argument · Official argument details

    Sources used for this argument breakdown

A citizen's guide to the whole case

What this case is about

The case tests the definition of willful violation under the Fair Credit Reporting Act. Safeco seeks a narrow standard. Burr seeks a broader standard covering reckless conduct.

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How the case got here

The Supreme Court heard oral argument in this case on January 16, 2007.

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What each side wants

Safeco wants the Court to limit willfulness to actual knowledge of a legal violation.

Burr wants the Court to confirm willfulness includes reckless disregard of legal duties.

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What each side says

Safeco argues Congress expressly required knowing violations elsewhere in the statute. It claims the absence of that language here implies a lower standard.

Burr argues the civil context of the statute supports a recklessness component. It claims the lower court correctly applied this broader definition.

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What the justices asked

Justice Scalia asked about reckless disregard.

Justice Breyer questioned the clarity of the term reckless in legal contexts. He asked about the difference between standards. He noted the Model Penal Code attempted clarification based on Court opinions. He asked if parties could not have been conscious of risk given their legal consultations. He asked if actual knowledge is required.

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Why it matters

The definition of willfulness determines liability for insurance companies. It affects how firms manage legal risk. It shapes the standard for civil penalties under the Fair Credit Reporting Act.

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What happens next

This article currently covers the argument record. Use the official docket link for later case activity.

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Official Court provenance

Official docket and case history · Official Supreme Court oral-argument detail page

Title and summary sources

Revision history

  1. Revision 1 · Official Transcript ·

    Correction: Rewritten to the concise citizen-facing editorial standard.

  2. Revision 2 · Official Transcript ·

    Correction: Migrated to the dated official Court activity contract without model use.

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