__NOTOC__ Safeco Insurance Co. v. Burr (consolidated with GEICO General Insurance Co. v. Edo), , is a United States Supreme Court case in which the court held that where "willfulness" is a statutory condition of civil liability, it generally includes both knowing violations of a standard and reckless violations..Elizabeth M. Bohn, Safeco v. Burr: Supreme Court Decides What "Willful" Violation Means under the Fair Credit Reporting Act, 61 Consumer Fin. L.Q. Rep. 612 (Fall 2007).S. L. Owens, Avoiding the Urkel Defense (Did I Do That): How Safeco Has (and Has Not) Begun to Provide an Affirmative Defense against Statutory Willfulness, 82 Def. Counsel J. 51 (January 2015).Alvin C. Harrell, Comment: Safeco Ins. Co. of America v. Burr, 61 Consumer Fin. L.Q. Rep. 614 (Fall 2007).
Safeco Insurance Co. of America v. Burr was consolidated with GEICO General Insurance Co. v. Edo in 2006.
Following the decision of the Ninth Circuit Court of Appeals, in 2006, a joint amicus brief was submitted to the U.S. Supreme Court, which had agreed to review the case, in support of petitioners Safeco and Geico by the Financial Services Roundtable, Chamber of Commerce of the United States of America, Business Roundtable, Mortgage Bankers Association, American Bankers Association, American Financial Services Association, America’s Community Bankers, and Consumer Bankers Association.
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