In Brown v. Mortensen, 2011 WL 2409912 (2011), the California Supreme Court held that FCRA only preempted claims against furnishers based on duties to provide accurate information and to take action upon being notified of a dispute and that FCRA did not preempt CMIA claims based on disclosure of medical information to CRAs.  See our discussion of the Court of Appeal decision here: http://www.calautofinance.com/?p=1033.