Paula Casillas v. Madison Avenue Associates, Inc, 926 F.3d 329

Madison Avenue Associates sent Paula Casillas a debt-collection letter under the Fair Debt Collection Practices Act (FDCPA) that omitted that disputes and requests for original-creditor information must be made "in writing."
Casillas filed a putative class action seeking statutory damages and fees under 15 U.S.C. § 1692k for the disclosure omission; she did not allege she tried or intended to dispute or verify the debt.
The district court dismissed for lack of Article III standing after this court’s precedential decision in Groshek (applying Spokeo).
The Seventh Circuit panel affirmed: a bare procedural omission that caused no concrete harm or appreciable risk to the plaintiff does not satisfy injury-in-fact.
The court declined to follow contrary authority (notably Macy in the Sixth Circuit) and rejected Casillas’s informational-injury and Havens-analogue arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Casillas has Article III standing for §1692g(a)(4)–(5) omission	Omission of the writing requirement is a statutory violation that itself creates concrete injury (informational injury)	Omission is a bare procedural violation that caused no harm or appreciable risk to Casillas	No standing; dismissal affirmed
Whether a bare failure to disclose statutory procedural requirements can alone confer standing	Deprivation of information is a concrete injury under Akins/Public Citizen/Havens	Spokeo requires a concrete, particularized injury or appreciable risk to plaintiff herself; mere statutory violation insufficient	Deprivation of information here is not a cognizable Article III injury absent harm or risk to plaintiff
Whether Robertson/Groshek line supports standing for procedural disclosure violations	Relies on Robertson for lost-opportunity theory	Groshek and Spokeo limit such theories where no risk to plaintiff is alleged	Court distinguishes Robertson; finds Groshek controls and bars standing here
Whether Sixth Circuit’s Macy decision is controlling/ persuasive	Macy: omission creates materially greater risk to consumers and thus concrete injury	Seventh Circuit: Macy conflicts with Spokeo/Groshek because Macy did not require risk to the plaintiffs themselves	Court declines to follow Macy; holds Macy inconsistent with Seventh Circuit precedent and Spokeo

Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (Article III requires a concrete, particularized injury beyond a bare statutory violation)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury-in-fact that is concrete and particularized, traceable, and redressable)
Groshek v. Time Warner Cable, Inc., 865 F.3d 884 (7th Cir. 2017) (procedural disclosure violations insufficient for standing absent concrete harm or appreciable risk)
Robertson v. Allied Solutions, 902 F.3d 690 (7th Cir. 2018) (lost opportunity to review substantive information can constitute concrete injury)
Macy v. GC Services Ltd. Partnership, 897 F.3d 747 (6th Cir. 2018) (holding omission of in-writing requirement under §1692g can create a materially greater risk of harm and confer standing)
Federal Election Comm’n v. Akins, 524 U.S. 11 (1998) (denial of information that statute requires to be public can itself be a concrete injury)
Public Citizen v. U.S. Dep’t of Justice, 491 U.S. 440 (1989) (denial of requested government records under disclosure statutes can constitute concrete injury)
Havens Realty Corp. v. Coleman, 455 U.S. 363 (1982) (statutory right to truthful information may be a legally cognizable injury when tied to the statute’s protected interest)