Russell Wendt v. 24 Hour Fitness USA, Inc., 821 F.3d 547

Plaintiffs Russell Wendt and Omar Jasso signed written membership contracts with 24 Hour Fitness and paid dues; they received full access to the gyms during their memberships.
Plaintiffs allege the contracts failed to comply with several technical provisions of the Texas Health Spa Act (the Act) and therefore are void ab initio.
Plaintiffs sought a judicial declaration of voidness, recovery of all membership fees paid in the past two years, punitive damages, interest, costs, and attorney’s fees; they also moved for class certification.
The district court dismissed for lack of Article III standing, concluding plaintiffs suffered no injury-in-fact because they received the benefit of the bargain (gym access).
On appeal, plaintiffs argued (1) they suffered economic injury because the contracts are void and they are thus entitled to refunds, and (2) a bare statutory violation of the Act alone suffices as an injury-in-fact.
The Fifth Circuit affirmed, holding plaintiffs suffered no actual damages and the Act does not create a standalone injury for purely technical, non-harmful violations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Article III standing — injury-in-fact	Contract noncompliance voids contracts, so Plaintiffs paid unlawfully and are entitled to full refunds (economic injury)	Plaintiffs received the benefit paid for (gym access); Act does not authorize disgorgement for harmless technical violations	No injury-in-fact; lack of Article III standing; dismissal affirmed
Statutory injury from bare violation	Mere violation of the Act is a legally protected right whose invasion confers standing	The Act conditions suit on a violation that "causes injury to the member" and limits recoverable relief to actual damages, equitable relief, punitive damages, and fees	Act requires actual injury; bare violations causing no harm do not confer Article III standing
Recoverability under Texas contract law	Void contract entitles plaintiff to recover full purchase price despite receipt of benefits	Texas law permits recovery only if plaintiff did not receive what was paid for or statute explicitly bars liability for past services	Plaintiffs received what they paid for; Texas law does not support full refund here
Class certification (procedural)	Motion to certify class pending	District court dismissed suit for lack of standing	Class-certification motion moot after dismissal for lack of standing

Lujan v. Defenders of Wildlife, 504 U.S. 555 (standing requires concrete, particularized, actual or imminent injury)
Warth v. Seldin, 422 U.S. 490 (standing can arise from statutory rights but plaintiff must be within statute's zone of interests)
Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (standing is a threshold jurisdictional question reviewed de novo)
Crane v. Johnson, 783 F.3d 244 (Fifth Circuit precedent on Article III standing analysis)