Thomas Robins v. Spokeo, Inc.
2014 U.S. App. LEXIS 2136
9th Cir.2014Background
- Spokeo operates a website that provides information about individuals, including Robins, whose data is allegedly inaccurate.
- Robins sued Spokeo for willful violations of the Fair Credit Reporting Act (FCRA).
- The district court dismissed for lack of Article III standing, finding Robins lacked injury in fact.
- Robins amended the complaint to allege specific misinformation and personal harms such as employment prospects and financial costs.
- The district court later reconsidered and dismissed, while the panel reversed and remanded for standing analysis.
- The panel held the district court could reconsider its prior standing ruling because it had not been divested of jurisdiction nor submitted to a jury.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Robins have Article III standing to sue for willful FCRA violations? | Robins claims statutory rights from FCRA exist as injuries. | Spokeo argues lack of concrete injury absent actual harm. | Yes, Robins has standing. |
| Did the district court properly handle law-of-the-case regarding reconsideration? | Law-of-the-case barred reconsideration of May 11 ruling. | Court could reconsider since it wasn't divested or juried. | Law-of-the-case did not limit reconsideration; district court could revisit. |
| Does FAC adequately allege injury in fact from statutory rights under FCRA? | Statutory rights themselves create concrete, individualized injuries. | Injury requires actual damages absent willful violations. | Yes; statutory violation suffices to allege injury at this stage. |
| Are causation and redressability satisfied for statutory-right injuries under FCRA? | Causation and redressability are implied by statutory violation and damages. | Unclear for causation and remedy without actual damages. | Causation and redressability adequately pled. |
Key Cases Cited
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing requires injury in fact, causation, redressability)
- Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., Inc., 528 U.S. 167 (2000) (injury-in-fact framework for standing)
- Fulfillment Servs. v. United Parcel Serv., Inc., 528 F.3d 614 (9th Cir. 2008) (statutory-right injuries can confer standing when private action exists)
- Edwards v. First American Corp., 610 F.3d 514 (9th Cir. 2010) (principles for standing with statutory rights)
- Beaudry v. TeleCheck Servs., Inc., 579 F.3d 702 (6th Cir. 2009) (statutory rights under FCRA can support standing)
- Beaudry v. TeleCheck Servs., Inc., 579 F.3d 702 (6th Cir. 2009) (injury-in-fact and statutory rights for FCRA)