Patrick Gray v. Trans Union, LLC, and Equifax Information Services, LLC

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION PATRICK GRAY, ) ) Plaintiff, ) ) v. ) No. 2:26-cv-02001-SHL-atc ) TRANS UNION, LLC, and EQUIFAX ) INFORMATION SERVICES, LLC, ) Defendants. ) ORDER DISMISSING DEFENDANT TRANS UNION, LLC, WITH PREJUDICE

Before the Court is Plaintiff Patrick Gray’s Notice of Voluntary Dismissal as to Trans Union, LLC, filed March 17, 2026. (ECF No. 12.) Gray seeks to dismiss Trans Union “with prejudice and on the merits” under Federal Rule of Civil Procedure 41(a)(1)(A)(i). (Id. at PageID 32.) Gray’s claims against Defendant Equifax Information Services, LLC, remain.

Because Trans Union, LLC, has not filed an answer or a motion for summary judgment, dismissal under Rule 41(a)(1)(A)(i) would normally be proper. However, in multi-defendant matters, “Rule 21 provides the appropriate basis for dismissal of a single defendant,” not Rule 41. Henderson-Thompson v. Jardoin, No. 22-cv-2013, 2022 WL 349896, at *2 (W.D. Tenn. Feb. 4, 2022) (citing Philip Carey Mfg. Co. v. Taylor, 286 F.2d 782, 785 (6th Cir. 1961)); see also Wilkerson v. Brakebill, No. 15-CV-435, 2017 WL 401212, at *2 (E.D. Tenn. Jan. 30, 2017) (collecting district court cases from within the Sixth Circuit recognizing that Rule 21, rather than Rule 41, is applicable when dismissing a single claim or defendant instead of an entire lawsuit).

The Court will therefore construe the notice under Rule 41 as a motion under Rule 21. See Henderson-Thompson, 2022 WL 349896, at *2.

Rule 21 permits a court to drop a party at any time on motion or on its own. Fed. R. Civ. P. 21. Dropping parties under Rule 21 functions as a dismissal of the party. See Henderson- Thompson, 2022 WL 349896, at *2. Thus, all claims against Defendant Trans Union, LLC, are DISMISSED WITH PREJUDICE under Rule 21. This dismissal does not apply to Gray’s claims against Defendant Equifax Information Services, LLC.

IT IS SO ORDERED, this 30th day of March, 2026. s/ Sheryl H. Lipman SHERYL H. LIPMAN CHIEF UNITED STATES DISTRICT JUDGE