Law School Case Brief
Spokeo, Inc. v. Robins - 136 S. Ct. 1540 (2016)
Standing to sue is a doctrine rooted in the traditional understanding of a case or controversy. The doctrine developed in the U.S. Supreme Court's case law to ensure that federal courts do not exceed their authority as it has been traditionally understood. The doctrine limits the category of litigants empowered to maintain a lawsuit in federal court to seek redress for a legal wrong. In this way, the law of Article III of the Constitution standing serves to prevent the judicial process from being used to usurp the powers of the political branches, and confines the federal courts to a properly judicial role. Cases have established that the irreducible constitutional minimum of standing consists of three elements. The plaintiff must have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision. The plaintiff, as the party invoking federal jurisdiction, bears the burden of establishing these elements. Where a case is at the pleading stage, the plaintiff must clearly allege facts demonstrating each element.
The Fair Credit Reporting Act of 1970 (FCRA) requires consumer reporting agencies to “follow reasonable procedures to assure maximum possible accuracy of” consumer reports and imposes liability on “any person who willfully fails to comply with any requirement [of the Act] with respect to any” individual. Petitioner Spokeo, Inc., an alleged consumer reporting agency, operates a “people search engine,” which searches a wide spectrum of databases to gather and provide personal information about individuals to a variety of users, including employers wanting to evaluate prospective employees. After respondent Thomas Robins discovered that his Spokeo-generated profile contained inaccurate information, he filed a federal class action complaint against Spokeo, alleging that the company willfully failed to comply with the FCRA’s requirements. The district court dismissed Robins' complaint, holding that he had not properly pleaded injury in fact as required by Article III. On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed. Based on Robins' allegation that “Spokeo violated his statutory rights” and the fact that Robins' “personal interests in the handling of his credit information are individualized,” the court held that Robins had adequately alleged an injury in fact.
Did the appellate court err in holding that Robins had standing to sue Spokeo?
The Court held that the injury-in-fact requirement for standing under Article III of the Constitution required a plaintiff to allege an injury that was both concrete and particularized. In the action under the Fair Credit Reporting Act of 1970, the appellate court's standing analysis was incomplete because it failed to fully appreciate the distinction between concreteness and particularization, and it did not address whether the particular procedural violations alleged in the case entailed a degree of risk sufficient to meet the concreteness requirement.
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