Kent v. HCL Technologies Limited, 2:24-cv-01332

Stephen Kent filed a proposed class action in King County Superior Court against HCL Technologies, alleging violations of Washington's Equal Pay and Opportunities Act (EPOA) regarding pay transparency in job postings.
HCL removed the case to federal court, asserting federal diversity jurisdiction under 28 U.S.C. § 1332(a) and (d).
Kent moved to remand, arguing removal was improper because he lacked Article III standing, similarly to several other recent EPOA cases.
The complaint alleged Kent applied for an HCL job whose posting did not disclose pay information, and claimed this caused him and putative class members lost time and inability to evaluate pay.
The district court considered the sufficiency of Kent's alleged injury and whether the omission constituted a concrete harm required for federal jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to disclose pay range gives Article III standing	Kent lost time and opportunity to evaluate and negotiate pay, harming concrete interests the EPOA protects	Kent suffered no real, concrete harm from the missing information	Kent lacks standing; no concrete injury alleged sufficient for Article III jurisdiction
Whether statutory violation alone is enough for standing	EPOA establishes a substantive right and violation itself suffices for standing	Not every statutory violation equates to concrete injury	Statutory right alone does not suffice; must allege actual or imminent, concrete harm
Applicability of prior remand orders in similar EPOA cases	Similar complaints have been remanded for lack of standing and subject matter jurisdiction	Each case should be considered on its facts	Persuasive authority; pattern of remands supports lack of standing in cases like Kent's
Whether jurisdictional discovery should be permitted	(Not substantively argued by Kent)	Discovery could clarify basis for standing	Not appropriate—complaint clearly shows lack of standing; discovery would not change outcome

Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) (plaintiff does not automatically have standing from a statutory violation; must show concrete harm)
TransUnion LLC v. Ramirez, 594 U.S. 413 (2021) (Constitutional standing requires concrete, particularized, actual or imminent injury)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (plaintiff bears burden to establish standing, must show injury-in-fact)
Warth v. Seldin, 422 U.S. 490 (1975) (no subject matter jurisdiction if standing is lacking)
Ariz. Christian Sch. Tuition Org. v. Winn, 563 U.S. 125 (2011) (Article III limits judicial power to cases and controversies requiring standing)