The United States Supreme Court recently handed down an opinion that may have broad implications for class action lawsuits. In Spokeo, Inc. v. Robins, the defendant maintained a search engine that allowed users to search specifically for people through its database. Employers could use the site to gain information about job applicants before deciding whether to hire them. The plaintiff discovered that the profile Spokeo provided for him contained numerous mistakes and other improper information. He brought a federal class action lawsuit against Spokeo, stating that it did not comply with the federal Fair Credit Reporting Act.
The lower court dismissed the lawsuit, stating that he had not adequately pleaded that he had suffered an actual injury as a result of the incorrect information in his profile. According to federal pleading standards, a plaintiff must establish that he or she has suffered a cognizable injury before being deemed entitled to compensation. This is known as the injury in fact requirement.
On appeal to the Ninth Circuit, the court reversed, finding that the plaintiff and other class members had an interest in how Spokeo handled their credit information. This was sufficient to establish an injury in fact, the court concluded.
Spokeo appealed the matter to the U.S. Supreme Court, which granted review of the matter. According to the high court, the Ninth Circuit did not fully analyze whether an injury in fact was sufficiently pleaded. The court described the injury in fact requirement as requiring the plaintiff to establish that he or she experienced “an invasion of a legally protected interest” that is “concrete and particularized” and “actual or imminent.” The harm cannot be merely hypothetical or conjectural. Applied to the Ninth Circuit’s analysis, the Supreme Court concluded that the appellate court failed to consider whether the plaintiff’s injury in fact was concrete. The appellate court had only considered the particularization requirement, which is that the injury affected the plaintiff personally and individually. Accordingly, the court reversed the Ninth Circuit’s ruling and remanded the action for further consideration.
This ruling underscores the importance of crafting a careful class action lawsuit and ensuring that you have satisfied all of the requirements. Based on this case, plaintiffs will need to show that they have actually been injured as a result of the product’s alleged defect.
The experienced and professional products liability lawyers at Moll Law Group have handled a wide variety of class action matters, including those related to dangerous drugs, defective medical devices, and toxic exposure. Navigating the federal legal system can be complex and daunting, especially if this is your first experience with bringing a lawsuit. Proudly serving clients nationwide, including in Illinois, New York, California, and Florida, we provide a free consultation to help assess your potential claim and to determine the legal remedies that may be available to you. Call us at 312-462-1700 or contact us online to schedule your appointment today.
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