On August 1, a Seventh Circuit panel declined to revive Fair Credit Reporting Act ("FCRA") lawsuits against a large cable television company and student loan provider, finding that the plaintiff had not demonstrated that he suffered injury to establish standing under the U.S. Supreme Court's Spokeo decision.
- On August 1, the D.C. Circuit revived a putative class action brought by policyholders against a large insurance company over a 2014 data breach, finding that the alleged heightened risk of identity theft and medical fraud was enough to establish standing under the U.S. Supreme Court's landmark Spokeo decision.
- On August 15, the Ninth Circuit, on remand from the U.S. Supreme Court, ruled that the plaintiff claimed a sufficiently concrete injury against Spokeo to meet the Article III standing requirements established by the Supreme Court. The Ninth Circuit held that the plaintiff met the standing bar by alleging an intangible statutory injury without any additional harm because Congress had crafted the FCRA provisions at issue to protect consumers' concrete interests in accurate credit reporting about themselves.
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