The scope of FCRA preemption remains a hopeless muddle, with courts adopting different theories that lead to very different results. A recent decision from West Virginia clearly describes all three leading theories, complete or total preemption, the temporal approach, and the statutory approach. Evans v. Trans Union LLC, 2:10-cv-00945, 2011 U.S. Dist. LEXIS 14724 (S.D. W. Va. Feb. 14, 2011). Recognizing that the Fourth Circuit has not taken a position on the issue, the court noted that district courts in the Circuit had uniformly adopted the statutory approach, and the court followed suit.