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Spokeo, Inc. v. Robins, 578 U.S. 330, 136 S.Ct. 1540, 194 L.Ed.2d 635, 100 Empl. Prac. Dec. P 45,556, 84 USLW 4263, 16 Cal. Daily Op. Serv. 4997, 2016 Daily Journal D.A.R. 4566, 26 Fla. L. Weekly Fed. S 128

Facts

Thomas Robins discovered that his profile on Spokeo, Inc., a website that aggregates personal information, contained inaccurate details about his life, including false claims about his marital status and education. He filed a class-action lawsuit against Spokeo, alleging that the company willfully failed to comply with the FCRA's requirements for accuracy in consumer reporting. The District Court dismissed his complaint for lack of standing, but the Ninth Circuit reversed, stating that Robins had adequately alleged an injury in fact.

Petitioner Spokeo, Inc., an alleged consumer reporting agency, operates a 'people search engine,' which searches a wide spectrum of databases to gather and provide personal information about individuals to a variety of users, including employers wanting to evaluate prospective employees. After respondent Thomas Robins discovered that his Spokeo-generated profile contained inaccurate information, he filed a federal class-action complaint against Spokeo, alleging that the company willfully failed to comply with the FCRA's requirements.

Issue

Did the Ninth Circuit properly determine whether Robins had standing to sue Spokeo under the Fair Credit Reporting Act, specifically regarding the injury-in-fact requirement?

Did the Ninth Circuit properly determine whether Robins had standing to sue Spokeo under the Fair Credit Reporting Act, specifically regarding the injury-in-fact requirement?

Rule

To establish standing under Article III, a plaintiff must demonstrate an injury in fact that is concrete and particularized, fairly traceable to the defendant's conduct, and likely to be redressed by a favorable judicial decision.

A plaintiff invoking federal jurisdiction bears the burden of establishing the 'irreducible constitutional minimum' of standing by demonstrating (1) an injury in fact, (2) fairly traceable to the challenged conduct of the defendant, and (3) likely to be redressed by a favorable judicial decision.

Analysis

The Supreme Court found that the Ninth Circuit's analysis was incomplete because it focused solely on the particularization of Robins' injury without addressing the requirement of concreteness. The Court emphasized that an injury must be both concrete and particularized, and that a mere procedural violation of the FCRA does not automatically satisfy the injury-in-fact requirement. The Court noted that the Ninth Circuit failed to consider whether the alleged procedural violations posed a sufficient risk to meet the concreteness requirement.

Because the Ninth Circuit failed to fully appreciate the distinction between concreteness and particularization, its standing analysis was incomplete. It did not address the question framed by our discussion, namely, whether the particular procedural violations alleged in this case entail a degree of risk sufficient to meet the concreteness requirement.

Conclusion

The Supreme Court vacated the Ninth Circuit's decision and remanded the case for further proceedings to determine whether Robins' allegations meet the concreteness requirement for injury in fact.

The judgment of the Court of Appeals is vacated, and the case is remanded for proceedings consistent with this opinion.

Who won?

The Supreme Court vacated the Ninth Circuit's ruling, effectively favoring Spokeo by requiring a more stringent analysis of standing based on the injury-in-fact requirement.

The Supreme Court vacated the Ninth Circuit's ruling, effectively favoring Spokeo by requiring a more stringent analysis of standing based on the injury-in-fact requirement.

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