Spokeo, Inc. v. Robins

Robins filed suit against Spokeo, Inc. for violating the Fair Credit Reporting Act (FCRA) by publishing false information about his economic status on its website. However, because Robins failed to allege that he experienced any “actual or imminent harm” as result of Spokeo’s conduct, the district court dismissed his complaint in part for lack of standing under Article III of the U.S. Constitution. In an amended complaint, Robins claimed that he had suffered the loss of potential employment because Spokeo’s website portrayed him as wealthier than he was. Although the district court initially denied Spokeo’s subsequent motion to dismiss, upon reconsideration it again dismissed Robins’ claims for lack of standing due to failure to allege sufficient injury.

Robins appealed, arguing that the district court could not reconsider its previous decision and that he had sufficiently alleged an injury in fact to qualify for Article III standing. Although the U.S. Court of Appeals for the Ninth Circuit held that the district court was permitted to reconsider its ruling, it reversed, finding that the allegation of a violation of a statutory right is sufficient injury to qualify for standing.

The U.S. Supreme Court granted cert on the issue of whether Congress may authorize a cause of action based on a violation of a federal statute and therefore confer Article III standing on a plaintiff who has not suffered concrete harm. Oral argument was held on November 2, 2015. Professor Erwin Chemerinsky of the University of California, Irvine school of law provided commentary here.

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